He had previously been breached for moving to an unapproved address and four times for having a cellphone capable of accessing the internet.
In September, Rainham was jailed on his fifth breach and released on October 23 with GPS tracking. But, on November 19, he was seen using a mobile phone in Pak'n Save by a probation officer who checked the phone and found it was internet capable.
Lawyer Jock Blathwayt told the court Rainham had picked up the phone after it was discarded, that it didn't have a SIM card in it and wasn't capable of accessing the internet.
"That is the position he is in."
Mr Blathwayt asked that Rainham be given a final warning.
Judge Morris stood the case down and ordered the phone be checked.
When court resumed, she heard the phone was Wi-Fi capable.
The judge told Rainham the order was in place to help him, as he had been determined to be at "high-risk of re-offending".
"It's critically important you don't access the internet."
She said it was far safer for Rainham not to have a cellphone at all.