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I've read on numerous occasions that the 'second season' syndrome is often a result of buying a heap of new players and trying to integrate them into an existing tactic. The subsequent dip in results is a direct result of this rather than the game's AI working out your tactic.
Does this occur if you buy players but don't play them in the first team straight away? I had a very succesful first season but have started the second season in a distinctly average vein of form. I did bring in a few new faces but so far I've been playing the same starting eleven as last year as much as is possible.
It is a combination of things including integration of new players but also the fact that the AI Managers have had a season to look at your tactics and team and have come up with different ways of combatting them. Your team will also have been re-ranked as to their ability and expectations and that affects AI mentality. You perhaps need to make some small changes to your team mentality to counter the AI tactics.