It fell short of Bill Callahan's "Dumbest team in America" label in 2003, but coach Hue Jackson questioned his team's smarts after the Raiders were flagged 15 times for 130 yards in a 38-24 loss to the Denver Broncos on Sunday.
"I think we're not a very intelligent football team right now," Jackson said. "We're not playing very intelligently when it comes to penalties. Some of them are uncalled for.
"We're going to continue to address it. I don't want anyone to think we haven't. We emphasize it, and we're not going to stop. It might be Game 16 when we get it fixed, I don't know."
The Raiders have a comfortable NFL lead for both penalties (84) and penalty yards (730) at midseason.
Should Oakland maintain that pace, it would break the existing record in both categories, held by the 1998 Kansas City Chiefs with 158 penalties for 1,304 yards. The Raiders team record, and the second-most all-time, is 156 penalties in 1996.
The most penalty yardage for the Raiders is last season's total of 1,276 yards, which ranks No. 2 all-time.
Oakland has led the league in penalties 16 times, tied with the Chicago Bears for the most in NFL history -- and the Bears led the league for the first time in 1941.
Although the Broncos eventually punted on the drive, one of the penalties that surely got Jackson's attention came when Aaron Curry hit Denver quarterback Tim Tebow out of bounds after he gained zero yards on a third-and-20. The Broncos got an automatic first down instead of having to punt.
"I've got to eliminate that stuff from my game, point blank, period," Curry said. "I shouldn't even have touched him, and I knew it as soon as I did it."
Jackson has had no shortage of suggestions for alleviating the problem.
"You can't take their money for penalties," Jackson said. "That's not how it works in the NFL. I wish it did. ... It's a problem, and we'll continue to address it and keep working on it."
Jackson said Heyward-Bey, the Raiders' leading receiver who had 22 catches in his last four games, simply wasn't involved in a lot of the packages the Raiders used. He had only one pass thrown in his direction, a deep ball into the end zone that fell incomplete.
Boss barely got in the game at all, Jackson said, because of the Raiders decision to use a lot of three-wide receiver, two-running back sets (that apparently didn't include Heyward-Bey).
Tight end Brandon Myers got on the field, however, and had one catch for 11 yards.
Wide receiver Jacoby Ford appears to have immediately built a connection with Carson Palmer, catching five passes for 105 yards and an 18-yard touchdown.
"I think we did really well with the things we worked on during the bye," Ford said. "He knew where he wanted the ball to be and I knew where I needed to be for us to make the completions."
Denarius Moore was targeted 12 times and caught four passes for 61 yards, and new addition T.J. Housmandzadeh had four targets, catching one for 28 yards.
Wide receiver Louis Murphy caught his first pass of the year, then promptly flung the ball away and received a penalty for delay of game.
Janikowski was inactive for the Raiders' last game before the bye against Kansas City with a hamstring pull.
"It felt good," Janikowski said. "On kickoffs, I was doing whatever I could. That's the hardest I could swing."