 The top New York teams were eventually absorbed into the NFL upon its founding in 1920, but the league (mostly driven by an Ohio League that did not have true championship games, though they frequently scheduled "de facto" championship matchups) did not adopt the New York league's playoff format, opting for a championship based on regular season record for its first twelve seasons; as a result, four of the first six "championships" were disputed.Technically, a vote of league owners was all that was required to win a title, but the owners had a gentlemen's agreement to pledge votes based on a score (wins divided by the sum of wins and losses, with a few tiebreakers).When two teams tied at the top of the standings in 1932, an impromptu playoff game was scheduled to settle the tie.