In November 2000 Mr Nkosana Makate, then a trainee accountant at Vodacom, devised the “Please Call Me” (PCM) service. An agreement was concluded with Vodacom representatives under which Makate would disclose the idea and, if successful, receive a share of revenue generated, with the Vodacom CEO to break any deadlock on quantum. After Vodacom launched the service in 2001 and earned billions of rand, Makate’s attempts to negotiate compensation were unsuccessful. Following prolonged litigation, in 2016 the Constitutional Court confirmed the existence of the contract and remitted the matter to the Vodacom CEO to determine reasonable compensation. The CEO awarded approximately R47 million. Makate launched review proceedings in the High Court (Hughes J), which set aside the CEO’s determination as unreasonable and patently inequitable, substituting its own remedial order. The Supreme Court of Appeal (SCA) majority (Mocumie JA, Mothle JA and Nhlangulela AJA) largely dismissed Vodacom’s appeal and ordered Vodacom to pay Makate 5% of the revenue earned from return calls made within the first hour of a PCM being sent, calculated over 18 years, together with interest and costs. Vodacom now seeks leave to appeal to the Constitutional Court. The text supplied is Makate’s opposing heads of argument, contending that the application raises no constitutional issue or arguable point of law of general public importance and that the SCA’s factual and discretionary findings cannot be impugned.