The systems-unconscionability case. High Court, 14 August 2024 — ⚠ verify reported as [2024] HCA 27 (Gageler CJ, Gordon, Edelman, Steward, Gleeson, Jagot and Beech-Jones JJ; six separate judgments). An online vocational college removed consumer safeguards from its enrolment and withdrawal processes to increase claims under the VET FEE-HELP scheme; over 90% of the affected consumers completed no part of their course and about 86% never logged in, while incurring substantial debts, and the college claimed over $50 million. Appeals dismissed. Three holdings to carry. (1) System of conduct — s 21(4)(b) applies 'whether or not a particular individual is identified as having been disadvantaged'; a system is found in 'practices, processes or methods, policies and patterns of behaviour... external, observable repetition of events', and exposing consumers to a reasonably foreseeable risk of the resulting misconduct suffices. (2) The threshold — Gageler CJ and Jagot J: conduct will not be unconscionable 'unless it is outside societal norms of acceptable commercial behaviour [so] as to warrant condemnation as conduct that is offensive to conscience'. (3) Section 22 is not a checklist — it 'does not require a court to evaluate the impugned conduct by reference to the presence or absence of the circumstances that provision specifies'. Also confirms accessorial liability: the parent company and the former COO were knowingly concerned in the system. Justice Gleeson's judgment is the fullest treatment of how s 22 helps identify both the applicable standard and the relevant circumstances.