paras [23] to [37], JTAC [2005] NSWCCA 345 esp at para [9]. The 'vulnerability' of victims refers to the vulnerability of particular victims, as by age or occupation, not the vulnerability of all members of the community to people like false pretenders: Tadrosse (2005) 65 NSWLR 740 at para [26]. In a case of a person drug dealing, it is an error to treat as an aggravating factor that potentially some of the buyers may have been vulnerable, because that is true of every offence of supply heroin: Ancuta [2005] NSWCCA 275 at paras [13] to [14]. It was held that it was an error to treat the 'vulnerability' of the victim in a manslaughter case simply because she was not, like the offender, a powerful man with violent tendencies: Williams [2005] NSWCCA 99 at paras [40] to [41]. Similarly it is an error to treat a victim as 'vulnerable' because he was unarmed: Regina v Nowak (2008) 183 A Crim R 526. It has been held that where taxi driver sexually assaults a drunken passenger that the vulnerability of the victim is an aggravating factor: Ali v Regina [2010] NSWCCA 35 Similarly it does not apply where charges are being taken into account on a Form One, because that involves double counting: Hamze [2006] NSWCCA 36 at paras [48] to [49]. (n) 'the offence was part of a planned or organized criminal activity' The fact there was 'a level of planning' in the commission of an offence does not