No. 14-5123 Page 12 Huff, et al. v. Spaw James Huff failed to exhibit an expectation of privacy, we need not determine whether circumstances justified such an expectation to conclude that his statements do not qualify as oral communications and therefore cannot give rise to liability under Title III. The Huffs warn that, if we do not recognize James Huff’s reasonable expectation of privacy in this case, we would deprive all cellphone-carrying Americans of their reasonable expectations of privacy in their conversations. Appellant’s Brief at 22. We disagree. Not recognizing James Huff’s expectation would do no more injury to cellphone users’ privacy interests than the injury that the plain-view doctrine inflicts upon homeowners with windows or webcams. A homeowner with an uncovered window or a broadcasting webcam lacks a reasonable expectation of privacy with respect only to viewers looking through the window that he neglected to cover or receiving signals from the webcam he left on. He would retain a reasonable expectation of privacy in his home with respect to other means of observation, for example thermal-imagery devices. Kyllo, 533 U.S. at 40. Similarly, James Huff retained an expectation of privacy from interception by non-pocket-dial means, such as by a hidden recording device or by someone covertly causing his cellphone to transmit his statements to an eavesdropper.7 See McCann v. Iroquois Mem’l Hosp., 622 F.3d 745, 753 (7th Cir. 2010) (holding that a defendant who secretly turns on a plaintiff’s dictaphone to record and acquire the plaintiff’s conversation would be liable under Title III). James Huff lacked a reasonable expectation of privacy in his statements only to the extent that a third-party gained access to those statements through a pocket-dial call that he placed. In sum, a person who knowingly operates a device that is capable of inadvertently exposing his conversations to third-party listeners and fails to take simple precautions to prevent such exposure does not have a reasonable expectation of privacy with respect to statements that are exposed to an outsider by the inadvertent operation of that device. ii. Bertha Huff’s Reasonable Expectation of Privacy from Interception Bertha Huff knew that her husband owned a cellphone and that cellphones were capable of inadvertently transmitting conversations to third-party listeners via pocket-dial calls. The 7 See Declan McCullagh and Anne Broach, FBI Taps Cell Phone Mic As Eavesdropping Tool, CNET NEWS, Dec. 1, 2006, available at http://news.cnet.com/FBI-taps-cell-phone-mic-as-eavesdropping-tool/21001029_3-6140191.html (last visited June 30, 2015).