I'm assuming this stat is based on teams that had 3 wins or more and no losses because there is a couple of times where he lost to 2-0 teams on the road which obviously bump the number up.
The 4 losses:
chargers 2002
saints 2009, worst Brady/Belichick Pats team and the saints were the best team that year
dolts 2009, yep again worst B/B era team. the 4th & 1 game
donkeys 2009, as you can see there is a theme with 3 of the losses.