Which of the following is not a bearer instrument?

A) An instrument payable to no one.
B) An instrument payable to "X."
C) An instrument payable to "cash."
D) An instrument payable to "bearer."
E) An instrument payable to "the order of John Doe."

Bearer instruments are negotiable instruments that allow the transfer of ownership to another party by possession alone. Options A, B, C, and D are considered bearer instruments because they do not specify a particular payee or endorse a specific individual, making them payable to whoever holds them. Option E, however, specifies "the order of John Doe," making it an order instrument rather than a bearer instrument. This means it is payable only to John Doe or someone he endorses it to, not to whoever holds it.