New Jersey, Comp. Stat. (1911), pp. 1640, 3776. A scroll or other device is sufficient.
New Mexico, Comp. Laws (1897), Sec. 3932. A scroll is sufficient.
New York, Gen. Const. Law, Sec.44. A seal shall consist of a wafer, wax, or other similar adhesive substance or of paper or other similar substance, affixed thereto by mucilage or other adhesive substance, or of the word seal or the letters L. S. opposite the signature.
Oregon, Lord's Oreg. Laws (1910), Sec. 775. Impression, wafer, wax, paper, scroll, or other sign made with a pen, constitutes a seal.
Rhode Island, General Laws (1909), c, 32, Sec. 14. An impression is sufficient,
South Dakota, Comp. Laws (1913), Sec. 2473. Like Rhode Island.
Utah, Comp. Laws (1917), Sec.Sec. 5726, 7105. A scroll, printed or written, or the word seal is sufficient.
Virginia, Code (1904), Sec.Sec. 5 (12), 2841. A scroll is sufficient.
West Virginia, Code (1913), 5344. A scroll written or printed is sufficient.
Wisconsin, Stat. (1916), Sec. 2216. A scroll or device as a seal is sufficient.
19Bertrand v. Byrd, 4 Ark. 195; Jackson v. Security Mut. L. I. Co., 233 111. 161, 84 N. E. 198; Whittington p. Clarke, 16 Miss. 480; Buckner v. Mac-kay, 2 Leigh, 488; Lewis v. Overby, 28 Gratt. 627; Osbora v. Kistler, 36 Ohio St. 99.
played no part in the determination of the question; but it will be observed that the extensions of the common law result in making the intention of the obligor of vital importance, for when almost anything may serve as a seal whether or not it is in fact a seal depends upon whether it was affixed or adopted as such, that is, upon whether it was intended to be a seal.20 If, however, a wafer or something appropriate for a seal was on the paper at the time of execution or was subsequently attached thereto by the signer in the place customary for a seal there is at least prima facie proof of the requisite intention.21