You can now read USC's 2009 defense against NCAA charges online (PDF).
After talking to many sources familiar with the investigation, it's clear that USC representatives believe the infractions committee didn't treat the program fairly -- not an unusual response from a sanctioned program, by the way -- and the university will take its issues to the Infractions Appeal Committee.
USC has two central contentions: 1. There's only tenuous evidence that connects running backs coach Todd McNair to the would-be sports agents, Lloyd Lake and Michael Michaels, who courted Reggie Bush with cash and lavish gifts; 2. That marketing representative Mike Ornstein was falsely named as a representative of USC athletic interests.
From USC's response to the NCAA:
In football, the NCAA Staff has attempted to establish a direct link between USC and the issues surrounding student-athlete 1 in two ways: (l) by pursuing unethical conduct charges against the assistant football coach for allegedly knowing about the benefits and failing to disclose them (Allegations I and 3); and (2) by pursuing a novel and flawed theory that a sports marketing agent became a representative of USC's athletics interests solely as a result of employing three USC student-athletes (including student-athlete l) in the summer of 2005. These allegations against the assistant football coach and USC are not supported by the evidence and should be rejected.
Suffice it to say, USC's defense isn't passive. One might, in fact, call it a bit combative with NCAA investigators.
USC believes the [NCAA] has pursued these weak institutional allegations in football because it recognizes that without a direct institutional link, the allegations surrounding Student-Athlete I involve only amateurism issues with no institutional violation. After 3 1/2 years of intensive public and media scrutiny, including repeated public questions as to why USC football has not yet been "brought to justice" by the NCAA, the pressure to accuse USC of having had actual knowledge of and a direct connection to the alleged impermissible benefits is very real.
In other words, USC believes the NCAA is kowtowing to pressure to make an example out of the school.
USC risks prolonging the controversy with an appeal, and it's unclear which portions of the NCAA's argument it will challenge. An appeal likely wouldn't be resolved until the spring of 2011 -- at the earliest -- so there is a risk in merely pushing the sanctions into the future.