Beating "cheese" tactics is never the issue...it is always possible to counter that kind of crap gameplay, the point is that its simply no fun after a while. 9 times out of 10, you stop somebody from doing the same stupid **** and they either accuse you of cheating and quit or they just quit outright...
If I wanted to play against someone running the exact same 2 or 3 plays every down, I would set up two controllers and go to town with it!
It will always be this way though...even if NFL 10 does turn out to be the sim-style game it is being hyped as, there will be a ton of online jokers who run no-huddle on every play (even incomplete passes), go for it on 4th and 20 from their own 15, and run an offense of 2-3 plays total. That is just the reality of the situation...finding players of a similar mindset and sticking with them for online games is a flat out must and always will be...