Background: Over the last 30 years, traditional skill-based game teaching models have gradually been supplemented by instruction under an inclusive banner of "Teaching Games for Understanding" (TGfU). This approach focuses on developing tactical understanding through modified games and a philosophy that places the learner rather than the game at the centre of instruction. A recent paper by Grehaigne, Caty, and Godbout, "Modelling Ball Circulation in Invasion Team Sports: A Way to Promote Learning Games Through Understanding", had a threefold focus: (1) to report the results of a qualitative study on various offensive configurations of football play observed in Physical Education (PE) lessons with young novice players; (2) to propose a model of game play based on the analysis of such configurations of play; and (3) to promote a radical constructivist teaching approach based on "learning games through understanding" that challenges the long-established TGfU methodology. Purpose: This paper critically examines the contention of Grehaigne, Caty, and Godbout that the presentation of tactical data collected through the observation of novices playing sport in ill-structured domains, e.g. team games such as football, represent a useful pedagogical model that promotes "learning games through understanding", In rewording the familiar TGfU approach, and calling it "learning games through understanding", Grehaigne, Caty, and Godbout challenge the evolving TGfU approach as too solutions based and not sufficiently student centred. Discussion: This paper challenges the use of radical constructivism as a construct for the development of a philosophy for instructing novices in team games, in this instance, football. It defines ill-structured and well-structured learning domains and suggests that effective pedagogy, the art of teaching, requires flexible attitudes towards the choice of pedagogy in games. By inference, it also challenges Grehaigne, Caty, and Godbout's assumption that the TGfU models previously published, e.g. TGfU, Game Sense, Play Practice, and interpreted in various texts, e.g. "Transforming Play, Teaching Tactics and Game Sense", are not student-centred and teacher dominated. Conclusions: Grehaigne, Caty, and Godbout's work is important in the evolution of models of game instruction for use in PE contexts. The concept of "learning games through understanding" is a timely reminder of the importance of pedagogies, for example, guided or discovery learning that induce effortful thinking. However, if we consider TGfU in its true philosophical light, that is, as a holistic and experiential approach to teaching, then it already encompasses "learning games through understanding". Because no two students learn or conceive knowledge in exactly the same way, teaching contexts require a flexible approach to instruction, based on a methodological continuum of empirical to radical constructivism. In short, providing novice learners with sufficient opportunities to learn, requires flexibility and a holistic experiential approach to teaching that is appropriate for the learner, activity and context.