The NFLPA complaints make the following claims:
1. Conduct prior to the new Collective Bargaining Agreement - August 4, 2011 - is not subject to discipline by NFL.
2. That only the CBA "System Arbitrator" (Stephen Burbank), not the Commissioner, should be able to punish the players because allegations of non-contract payments fall under Burbank's authority under the new CBA.
3. That even if the first two are somehow not controlling, the appeals should be handled by Art Shell and Ted Cottrell, the pair appointed by the NFL and NFLPA to judge appeals of punishments for "conduct on the playing field with respect to an opposing player or players."