White Ray is useful because it is about a small business, not just a national brand. The agency marketed properties using indicative prices that did not match what it expected the properties would sell for. Those expectations appeared in vendor documents or internal communications, which made the gap between public price and internal expectation hard to explain away.
The Court accepted agreed facts and imposed a $600,000 penalty. The judgment records that the agency accepted it did not have adequate systems to ensure its property price representations complied with the Australian Consumer Law.
The lesson travels beyond real estate. If your business gives customers a guide price, estimate, quote range or headline saving, the public number should be backed by the same internal information your team is actually relying on.