No. 14-5123 Huff, et al. v. Spaw Page 16 omitted). Spaw argues that she “did not mechanically or physically manipulate the line, so no interception occurred.” Appellee’s Br. at 25. We find this argument unconvincing for two reasons. First, the Williams court relied upon a misreading of Rathbun v. United States, 355 U.S. 107 (1957), by State v. Vizzini, 278 A.2d 235, 237 (N.J. Super. Ct. App. Div. 1971), to conclude that interference is a prerequisite for interception. In Rathbun, the Supreme Court considered the meaning of “intercept” under a former provision of the Federal Communications Act of 1934, 47 U.S.C. § 605 (“No person not being authorized by the sender shall intercept any communication and divulge or publish . . . such intercepted communications to any person.”), and held that no “interception” had occurred when one of two parties to a telephone conversation permitted a third party to surreptitiously listen on an extension line. 355 U.S. at 111. The Court reasoned that “[e]ach party to a telephone conversation takes the risk that the other party may have an extension telephone and may allow another to hear the conversation.” Ibid. The Vizzini court interpreted this to mean that, “[s]o long as the physical integrity of the established line is not violated, there is no interception.” 278 A.2d at 237. Williams adopted this interpretation, 507 P.2d. at 1341–42, and in doing so, conflated a sufficient condition with a necessary one. While third-party interference with the phone line was one way to intercept communications, the use of an unaltered phone line without the consent of either party would also qualify as interception. Laughlin v. United States, 344 F. 2d 187, 191–92 (D.C. Cir. 1965) (holding that a § 605 interception had occurred when a party’s consent to third-party eavesdropping through an unaltered extension line was obtained through coercion). Therefore, non-interference with a phone line does not, by itself, prevent an instance of phone-based eavesdropping from qualifying as an interception if the eavesdropping occurred without the consent of at least one party to that conversation, as is the case with the Huffs. Second, the Vizzini court mistakenly treated § 605 interception as being interchangeable with Title III interception, 278 A.2d at 237, and Williams adopted this treatment, 507 P.2d at 1341. Title III defines interception more broadly than did § 605.9 Even if the Supreme Court 9 For example, the two statutes differ as to whether interception is possible where one party consents. In Rathbun, the Supreme Court held that no § 605 interception occurs where a party consents to eavesdropping, 355 U.S. at 111. However, 18 U.S.C. § 2511(2)(c) makes clear that Title III interception can occur despite party