The NFL has fined Giants S Kenny Phillips $20,000 for an illegal hit on Seahawks TE Zach Miller.
Phillips was also flagged on the play for striking a "defenseless" receiver in the first quarter of the Giants' 36-25 loss.
This is the second time Phillips has been fined for a hit this season. He was fined $10,000 for an illegal hit to the head and neck area of Redskins TE Fred Davis in Week One.