I would buy the 63 out of this bunch. PCGS says one is a "gem" and the other two aren't? Meh. They've certified counterfeits. I'd guess 63, 64, 65 in order for this exercise.
Generally, whatever the buyer deems! As an ongoing experienced buyer of 70 years I believe to have seen a good selection of what might be considered "improperly graded" coins. An example is that I recently purchased from a novice female seller a 1922 PCGS graded MS63 Caced Double Eagle that to the human eye is "technically flawless". I have "rubbed", "bag-marked", "un-even luster" MS66 TPG Top-Tier graded coins of that type. Which is correct? I believe my opening statement, as the Numismatic market, and others, have deferred to same, JMHO
When I was building my early commemorative type set, I had a Roanoke in a PCGS MS-65 holder. Then I bought an MS-64 graded piece. I liked it better and committed “registry suicide” by keeping the MS-64 and selling the 65. I really can’t grade these pieces from the photos. They all seem to have great luster, which often trumps marks for the graders. The photos are like the PCGS Truviews that seem to make coins look better than they are. My photos always show the warts, sometimes to a grater extent than they really are.
Herein lies the "discussion" that @RussHJB was trying to pursue. We currently own 4 PCGS MS 64 Roanokes and they ALL look quite different. I think that, especially from pictures online, coins can be very difficult to grade from online photos, but sometimes that's all we have. Truthfully, I have seen the coins in hand. They weren't easy to identify by grade in hand.
For anyone that was curious: #1 MS63 #2 MS64 #3 MS65 I've posted these pictures posing the same question on multiple forums across the internet and a whole lot of respondents picked or preferred #1 as the MS65. The whole point to this was to get a discussion going about the already subjective nature of grading and the difficulty of grading from photographs. In hand I actually prefer #1, the MS63 coin myself.
#1=63- subdued luster #2=65- The strike looks very strong to me #3=64- good luster, but weaker on the strike