The NRL's new shoulder charge laws were meant to simplify the rule for both fans and the judiciary.
But as the ban on the controversial hit enters it's fifth year, it seems players' lawyers have just found it easier to defend.
South Sydney captain Sam Burgess became the third player to be cleared of a shoulder charge at the NRL judiciary this year on Tuesday night, each on the basis that they were bracing for contact in the defensive line.
North Queensland's Matt Scott was the first to make the argument after his round-two contact on Brisbane's Korbin Sims, while Ryan James had the added defence of being bumped by teammate Jarrod Wallace when he hit North Queensland's Patrick Kaufusi a fortnight later.
Cowboys star Jason Taumalolo now stands as the odd one out - he copped two matches for when it was proven he didn't use his arms to hit Brisbane's Alex Glenn last month.
Five other players have also been suspended for the act, after entering early guilty pleas.
Under new rules in 2017, for a hit to be considered a shoulder charge, the point of contact from the defender must be forceful and from the shoulder or upper arms, with no attempt to wrap the arms in the tackle.
The new wording also took away the controversial successful terminology between arm and side, which had helped players avoid being charged or found guilty in 2016.
Burgess argued in an hour-long hearing on Tuesday night that his contact point with Canterbury's Greg Eastwood in the Rabbitohs' Good Friday loss was with his chest, neck and jaw.
The 28-year-old also argued that Eastwood had initiated the collision, and that he was merely bracing himself in an attempt avoid himself being hurt.
"His shoulder is actually in my jaw," Burgess told the panel.
"It's physically impossible for that to happen if I'm making a shoulder charge.
"I've not intentionally not used my arms. I've braced as the collision is about to happen."
Meanwhile the NRL's counsel Peter McGrath pointed out Burgess' lack of effort to use his arms in the tackle, and claimed he had turned his left shoulder into Eastwood.
"You've transferred weight to your left foot," he said.
"You've leant forward with your upper left arm."
Burgess took little risk into the hearing, given he would've been banned for clashes with Brisbane and Manly had he took the early guilty plea, or lost at the panel.
But instead he emerged a winner, after the three-man judiciary panel of Dallas Johnson, Tony Puletua and Mal Cochrane took half an hour to side with his version of events.
"I'm looking forward to playing this week," Burgess said afterwards.
"It was a fair hearing. It wasn't a shoulder charge."
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