No. 14-5123 Huff, et al. v. Spaw Page 2 _________________ OPINION _________________ BOGGS, Circuit Judge. This case requires us to consider whether a person who listens to and subsequently electronically records a conversation from an inadvertent “pocket-dial” call1 violates Title III of the Omnibus Crime Control and Safe Street Act of 1968, 18 U.S.C. § 2510 et seq. (Title III). James Huff inadvertently placed a pocket-dial call to Carol Spaw while he was on a business trip in Italy. Spaw stayed on the line for 91 minutes and listened to face-to-face conversations that James Huff had with Larry Savage, James’s colleague, and with Bertha Huff, James’s wife. Spaw transcribed what she heard and used an iPhone to record a portion of the conversation between James and Bertha Huff (the Huffs). The Huffs brought suit against Spaw for intentionally intercepting their private conversations, in violation of Title III. The district court granted summary judgment for Spaw on the ground that, because James Huff placed the pocket-dial call, the Huffs lacked a reasonable expectation that their conversations would not be intercepted, which is a prerequisite for protection under Title III. This appeal followed. We affirm in part, reverse in part, and remand for further proceedings. I. BACKGROUND James Huff was Chairman of the Kenton County, Kentucky, Airport Board (Airport Board), which oversees the Cincinnati/Northern Kentucky International Airport (CVG). In October 2013, he traveled to Bologna, Italy with his wife, Bertha Huff, and with Airport Board Vice Chairman Larry Savage to attend a business conference. Carol Spaw worked at CVG as Senior Executive Assistant to the airport’s CEO, Candace McGraw, and as liaison to the Airport Board. Her work responsibilities included making travel arrangements for board members. After a conference meeting on October 24, James Huff and Savage went on an outdoor balcony in their hotel to speak about CVG personnel matters, including the possibility of 1 The term “pocket-dial” refers to the accidental placement of a phone call when a person’s cellphone “bump[s] against other objects in a purse, briefcase, or pocket.” Fed. Commc’n Comm’n, Accidental 911 Calls from Wireless Phones Pose Risk to Public Safety, available at http://www.fcc.gov/guides/accidental-911-callswireless-phones (last visited June 30, 2015).