Plaintiff’s faithless manager embezzled $154,000 by taking checks payable to plaintiff, endorsing them with a squiggle that might have approximated his name, and depositing them in his own account at JPMorgan. Because the deposits were by ATM and each check was for less than $1,500, no human inspected them. Held, the trial court erred in granting JPMorgan summary judgment. JPMorgan failed to prove that the manager had endorsed the checks in a manner that purported to be the endorsement of plaintiff, his employer. Proof of that fact is a prerequisite to reliance on the forgery by employee defense of UCC 3405. Questions of fact were raised regarding JPMorgan’s defense under UCC 3406 as there was conflicting evidence as to whether plaintiff was negligent and whether its negligence contributed to the forgeries.)