While there is no Same-Side Exterior Angles Theorem given, same-side exterior angles are

Answer:
Same-side exterior angles are Supplementary, not congruent.
Step-by-step explanation:
According to the Consecutive Exterior Angles Theorem, If two parallel lines are cut by a transversal, then alternate exterior angles are supplementary.
If the transversal cuts across parallel lines, then the exterior angles are supplementary, and not congruent.
The measurement of angle 1 (m < 1 ) should have been 108° and not 72°. The sum of m < 1 and the other alternate exterior angle with a measurement of 72° is 180.°
Therefore, same-side exterior angles are supplementary, not congruent.