Tell you what.....I'll concede your point about the lack of holding penalties against Husker opponents, as I have too many other things to spend my time on besides watching a Nebraska-Minnesota game from whenever.
However, I challenge you to look up the average number of penalties per game by school. The ones you will constantly see in the top 25% for fewest penalties are schools like Duke, Vanderbilt, Army, Navy, Air Force, Northwestern, Rice, etc. That was my point regarding ACT scores--smart players tend to make fewer dumb penalties. Yes....I'm sure NW's football team doesn't have an average of 33 on their ACT. I'd also bet that Nebraska's average isn't 25.
I also clearly illustrated how Nebraska was averaging 10 penalties a game heading into last year's game against Northwestern (who was averaging 3 per game), and how both teams were flagged for their season low up to that point (9 for Nebraska, 1 for Northwestern)....ergo debunking the silly "bias" argument.