Three Check: Checkmate or 3rd Check?

I'm just curious, if a checkmate is the third check, does it count as a victory by checkmate or by the third check?
I know it really doesn't matter, but still.

Checkmate counts as a Victory for the side who Checkamtes in 3 check Games.

@BDWH: I was about to creat a topic about this.

I think it will be like this:

Three checks and checkmate • Someone is victorious