No. 14-5123 Page 11 Huff, et al. v. Spaw allowed a user to turn off the file-sharing function, but the defendant neglected to do so. The Ninth Circuit concluded that “[t]o argue that Ganoe lacked the technical savvy or good sense to configure LimeWire to prevent access to his pornographic files is like saying that he did not know enough to close his drapes.” Id. at 1127. The principle that a person does not exhibit a reasonable expectation of privacy when he knew or should have known that the operation of a device might grant others access to his statements or activities is applicable in the Title III context as well. In McKamey v. Roach, the plaintiffs brought a private Title III action against the defendant for intercepting their phone conversations where one plaintiff used a cordless phone. 55 F.3d 1236 (6th Cir. 1995). Because Title III expressly excluded “the radio portion of a cordless telephone communication” from the definition of wire communication at the time,6 18 U.S.C. § 2510(1) (1988), the plaintiffs sought to characterize their conversations as oral communications. Id. at 1239. We rejected this characterization, reasoning that the plaintiffs could not enjoy a reasonable expectation of privacy in their cordless-phone conversations because “cordless telephone communications are broadcast over the radio waves to all who wish to overhear,” and the plaintiffs knew or should have known of this risk because the owner’s manual provided an explicit warning. Id. at 1239–40. At his deposition, James Huff admitted that he was aware of the risk of making inadvertent pocket-dial calls and had previously made such calls on his cellphone. A number of simple and well-known measures can prevent pocket-dials from occurring. These include locking the phone, setting up a passcode, and using one of many downloadable applications that prevent pocket-dials calls, see, e.g., Will Verduzco, “Prevent Unwanted Butt Dialing with Smart Pocket Guard,” xdadevelopers, Apr. 15, 2014, available at http://www.xda- developers.com/android/prevent-unwanted-butt-dialing-with-smart-pocket-guard/ (reviewing a smartphone application designed to prevent pocket-dial calls from occurring) (last visited July 8, 2015). James Huff did not employ any of these measures. He is no different from the person who exposes in-home activities by leaving drapes open or a webcam on and therefore has not exhibited an expectation of privacy. See Ganoe, 538 F.3d at 1127. Having determined that 6 In 1994, Congress amended Title III to remove the cordless-phone exemption, and thus made interception of cordless-phone conversations actionable as an interception of wire communication. COMMUNICATIONS ASSISTANCE FOR LAW ENFORCEMENT ACT, Pub. L. No. 103-414, § 202(a), 108 Stat. 4279 (1994).