No...but it would bolster her claim that a hostile work environment was knowingly perpetuated, which is a component of harassment. I'm not saying that talking to management is a trivial thing, especially in cases of reporting harassment. But it's also unfair to argue "they should've stopped it" if they weren't appraised of the situation. Again, maybe Horvath did say so, but her account to TechCrunch doesn't mention it explicitly. In any case, such a thing would likely be an electronic record, and so if she feels that the record was not thoroughly examined, now's her chance to assert that.