There are three main reasons I say this.
1. Both teams have completely (well,almost) changed their receivers. This changes the effect greatly, since there could be more or less offense. Also, the effect of Manning and Brady having to make a completely different game plan is key, which brings us to number…
2. Both teams have completely different game plans from last time. The Pats will try and get short yardage catches with Gronk, Hernandez, Welker, Branch, Edelman and Ochocinco. The Giants will try and get as much as they can, as they did against the Falcons, Niners, and Packers. The game is always made by the gameplan
3. New England is really the underdog. Everybody says the Giants will win, because they beat em’ before and they can do it again, etc. So the Pats (even though they are favored by 3.5) are really the underdog. But, one thing that’s notable, the Pats beat the Giants in the regular season in 07′ and lost in the Super Bowl – and Tom Brady has quite the motivation.
So, it’s going to be a completely different game.