How have courts interpreted the meaning of the word "making" in the context of a forged check?

The district court correctly rejected this argument. Relying on Reed, supra, and United States v. Chestnut, 533 F.2d 40, 46-47 (2d Cir.), cert. denied, 429 U.S. 829, 97 S.Ct. 88, 50 L.Ed.2d 93 (1976), the court examined the "key verbs" that 18 U.S.C. 513(a) uses in defining the offense. Distinguishing the verb "utter" from the verb "make," the court stated:

Unlike "uttering" which requires solely the act or declaration that something is good or the offer to show what is good, "making" is a verb connoting a broader spectrum of action. To make or create you need to bring something into being and to do so in the context of a forged check requires some ingredient. Here, the making of the forgery required both the checks and the traceable signature from Manhattan. Given the nature of this task to be performed, obtaining the ingredients was the beginning of the making, not the acts preparatory to the making.

United States v. Delia, at 503 (citations omitted).

The court further stated: