On September 3, Judge Richard M. Berman of the United States District Court for the Southern District of New York vacated Brady's suspension; this ruling allowed Brady to play in the first four games of the 2015 NFL season. In his decision, Judge Berman cited the NFL's failure to provide proper notice to Brady of the charges against him and the potential for a suspension. Post-appeal commentary also criticized Goodell for "manipulating Brady's testimony" at the appeal hearing in his decision.