Not only that, but even for those checking while driving, how many people now put the phone down below the dash, where they really can't see traffic when lookin

Not only that, but even for those checking while driving, how many people now put the phone down below the dash, where they really can't see traffic when looking at it, vs. holding it up in the air where they can glance back an forth (not that this is really safe either, but looking down at your lap is much worse).