The BCS era repeatedly produced undefeated teams that were never allowed to play for the national championship, exposing the system's built-in preference for the six automatic-qualifying conferences and Notre Dame. Tulane went unbeaten in 1998; Marshall did the same in 1999; Utah finished undefeated in 2004 and 2008; Boise State went unbeaten in 2004, 2006, 2008, and 2009; Hawaiʻi did it in 2007; and TCU finished unbeaten in 2009 and 2010. None received a championship-game invitation. The controversy became especially sharp in 2008, when Utah and Boise State were both undefeated but the rules effectively guaranteed only one non-AQ team access to the lucrative BCS bowl structure. A two-loss Ohio State team was selected for the Fiesta Bowl instead of Boise State, leaving the Broncos outside the BCS games despite being unbeaten for the second consecutive season and for the fourth time in six years. In 2009, TCU and Boise State again finished unbeaten; they were eventually paired in the Fiesta Bowl, but neither had been given a genuine path to the championship game. TCU's résumé included road victories over Clemson and Virginia, plus dominant wins over BYU and Utah, yet critics still believed the Horned Frogs were denied a chance to challenge Alabama. The so-called 'BCS Busters' went 5–3 in BCS bowl games, demonstrating that the outsiders could compete, but the system continued to treat their success as an exception rather than proof of equal access.
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