Gold Coast Titans CEO Graham Annesley has requested that the NRL review not only the club's three cases named in a breach notice around concussion protocols but the manner in which breach notices are issued after submitting an exhaustive 16-page response on Monday.

The Titans were issued a breach notice seven days ago in relation to alleged breaches of the concussion rules surrounding Ryan Simpkins, Kane Elgey and Joe Greenwood in their Round 3 clash with the Eels with fines if they are found to be guilty to reach $150,000.

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Concussion breach notices

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Simpkins was the only one of the three to leave the field against Parramatta but he was cleared to return by the Titans medical staff while neither Elgey nor Greenwood left the field.

The Titans will contend that Elgey stayed down for fear that he had suffered a broken jaw rather than a concussion and that Greenwood's apparent imbalance was caused by a poke to the eye and will be anxiously awaiting the NRL's findings.

The NRL issues breach notices after Chief Medical Officer Paul Bloomfield has reviewed footage of incidents from the weekend's games and while clubs are given five business days to respond, Annesley has questioned whether the club's medical staff should be consulted prior to any breach notices being issued.

"Our submissions do go into some of that detail," Annesley said.

"I don't want to foreshadow what's actually in the submission because I think that we need to do these things through the correct procedure but we haven't just referred to the three incidents, we've also talked a bit about process.

"The breach notice system is not new, it's been around for a long time and in some cases breach notices aren't issued immediately. Player misconduct is one of those areas, off-field misbehaviour if you will.

"There is usually an investigation that takes place before a breach notice is issued so we've made some observations about that in our submission and hopefully the NRL will give that due consideration and we'll get some answers from them soon."

When Elgey went down against the Eels, the Titans doctor and chief physiotherapist were both attending to Konrad Hurrell who had been taken off the field for a head injury assessment only moments earlier.

Shortly thereafter Elgey took a penalty kick into touch showing no ill effects, while in the case of Simpkins he passed all tests administered under the HIA protocols before being allowed to return.

Admitting that the Titans' medical staff were "shocked" when the breach notice was issued, Annesley commended their conduct in the manner of player welfare.

"I've got absolute confidence in our medical staff," said Annesley.

"Clearly they've got ethical and professional responsibilities that they carry out. There's no question that the medical staff would not take any decisions that weren't in the best interests of the players.

"The rules are pretty stringent and what this comes down to is a disagreement over the application of the rules and it's up to the NRL to determine whether out case has got any merit or not.

"We believe we have put a strong case forward and the way the breach notice system works is that you're not immediately found guilty of anything.

"The NRL forms an initial view that there may have been a breach of the rules and then clubs have the opportunity to put a case forward to convince the NRL otherwise.

"No one has been found guilty of any wrongdoing and we've got absolute confidence in the integrity and professionalism of our medical staff to do the right thing by our players."

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