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March 18, 2019

Apereo Foundation

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Join us at Open Apereo 2019 June 2nd to 6th | Omni Los Angeles Hotel at California Plaza

by Michelle Hall at March 18, 2019 04:38 PM

Open Apereo Registration Now Open

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Join us at Open Apereo 2019
June 2nd to 6th | Omni Los Angeles Hotel at California Plaza

by Michelle Hall at March 18, 2019 04:38 PM

March 13, 2019

Michael Feldstein

A Blackboard Debt Update, and a Lesson on Public Relations

The short version of this story is that Blackboard has sold off their Transact business and moved their corporate headquarters out of Washington, DC. Both of these are sensible moves that give them an opportunity to reduce their debt load and get on better financial footing. Not being a debt expert with access to the information to the information that credit rating agencies have, I can't comment at this point on how much this improves their outlook.

That should be the sum total of this post. Unfortunately, because Blackboard handled some of our previous coverage poorly, the news also provides evidence that they weren't entirely forthright with us in previous conversations about the tools they had at their disposal for handling their debt. So I'm obliged to complicate the news with an accountability story. Since I am weary of writing accountability stories after 14 years of writing them, I prefer to turn this story into a lesson about how ed tech companies can handle difficult PR situations better, in the hopes that I will have to write fewer of these stories in the future.

If what you mainly care about is Blackboard's financial health, then you can stop here. If you're interested in learning more about how ed tech companies accidentally get themselves into unnecessary trouble, and how they can minimize their chances of doing so, then read on.

Asking for Trouble

Back in the summer of last year, I got into two consecutive spats with Blackboard, neither of which I saw coming. The first was about our data showing that Instructure Canvas had surpassed Blackboard in US market share. Now, everybody, including Blackboard, knew that those market share lines where moving closer together. Counting methodologies being complex and legitimately debatable, it's possible to have honest disagreements about how close they are or whether they have crossed at any given moment. But we considered this more of a milestone that summed up a long-term trend than a big story in and of itself.

There were a couple of ways that Blackboard could have handled this. One was to play it to the hilt. Being branded—pun intended—as the corporate juggernaut has been a problem for Blackboard for a long time. They could have finally turned the tables on Instructure and portrayed themselves as the scrappy underdog. Or they could have just kept quiet and let the story pass. It would have disappeared down the memory hole in about three days. Instead, they engaged in a strong public pushback against our numbers. That doesn't make them bad people; they have a right to defend themselves as they see fit. But from a purely strategic perspective, their choice had the effect of both prolonging their bad news cycle and provoking responses from us.

In one of those responses, I tried to explain—again—that the market share lines crossing really wasn't news but rather a symbol of the ongoing trend. If you want real potential bad news for Blackboard, I argued—and this is where the danger of prolonging the bad news cycle caused further complications for them—you should look at their debt situation:

The real issue of concern is the potential behavior of their debt and equity owners. I'll come back to the point about Blackboard's total product portfolio in that context....

The second "Blackboard alert" article worth reading is the one by Katherine Doherty and Eliza Ronalds-Hannon at Bloomberg News. This one wasn't a reaction to our piece but rather coincidental timing triggered by the same underlying concerns. I spoke with Doherty, whose beat includes companies with distressed debt.

The debt is the real existential issue. Without it, Blackboard would just be a company that continues to struggle with its flagship product but which would have enough runway to turn itself around over time, one way or another. In the Bloomberg article, Blackboard CEO Bill Ballhaus repeats Miller's reminder that the company sells other products and services. And as we have pointed out repeatedly here on e-Literate, the international markets are an increasingly large percentage of Blackboard's financial picture. The fundamentals of the company may not be great, but they're not dire either. Given time, good leadership, and low debt, a company in this position should be able to right itself.

But because Blackboard has high debt, their situation potentially a lot more volatile. One major reason why the market share milestone matters is that it's an apt metaphor for Blackboard's financial waterline. At their current debt levels, the company can't afford for their market share to continue to drop.

Contract losses have sent Blackboard’s revenue and earnings sliding, according to people with knowledge of the matter, making it harder to carry more than $1.3 billion of rated debt. With some of Blackboard’s bonds selling at deeply distressed levels, Ballhaus is crafting a comeback, and possible options include the sale of its payment processing division, said the people, who asked not to be identified because the discussions are private.

So, I wrote that Bloomberg news reported that Blackboard has debt levels that are high enough to cause potential problems for its business. Elsewhere, we reported that Moody's had made some negative comments about their debt as well. Reporting these things is a little like reporting that the Weather Channel is predicting a high likelihood of heavy snow. It's not something you argue about.

I went on to say that, while the debt situation was serious for Blackboard, it was far from certain doom:

Even in this situation, the results for Blackboard Learn customers won't necessarily be bad, or even noticeable—depending on how the finances are resolved. If Blackboard sells off Transact, gets a good price for it, pays down some debt, and otherwise sticks with the current management's plan, that could buy them some time and some ability to survive further erosion of market share around Learn. If the company's owner, Providence Equity, decides to take more drastic steps, then the potential impact on customers is unpredictable. And Providence's calculations regarding how much drastic action is required must be at least partly driven by their assessment of how close Blackboard is to bottoming out in LMS market share loss.

This story was harder for the company to ignore, but they still had some options. I had said some good things about the company in that post, and some critical things about their competition. Their CEO, Bill Ballhaus, is a turnaround specialist. The Private Equity owners of Blackboard have signaled their trust in him by making him both Chairman and CEO. They had a good story line there. And they were going to have an option to engage with us in person very soon at BbWorld.

So what strategy did they choose?

Keep digging

They pushed back hard. We had two meetings with Blackboard executives, including our meeting with Bill Ballhaus, in which they brought up the debt issue immediately and completely dismissed it as illegitimate. This was what poker players call a "tell." It was so far out of the norm for this sort of analyst/executive meeting that it sent a clear signal of how concerned they were about the coverage. Now, some of that is simply due to the fact that people read what we write and react to it, and they don't always read it carefully. So we know that Blackboard got inbound calls that were triggered by that post. But the tone of the pushback, coupled with the implausibility of the arguments, were highly inconsistent from our experience with this management team.

This instantly changed the story line of BbWorld for us, and not in a way that Blackboard had intended. Here's what I wrote in my follow-up post, entitled "Blackboard's Defenses of Its Finances Are Not Persuasive," about that meeting:

When we were at BbWorld the week before last, Blackboard's executive management pushed back vehemently on our analysis of how their high levels of debt could impact their business decisions. We heard their strong disagreement expressed in our very first meeting of the conference from Chief Learning and Innovation Officer Phill Miller and in our very last meeting from CEO Bill Ballhaus.

We stand by our analysis. In fact, Blackboard's pushback had the opposite of its intended effect. We left BbWorld more convinced that we are right rather than less....

Ballhaus argued to us that the amount of debt that Blackboard is carrying is a strategic choice that he and the private equity investors—he used the pronoun "we"—make together. In particular, he argued, "we" could choose at any time to invest more money in the company, paying down debt in exchange for equity. Further, he argued, it's logical to assume that Providence would do so if needed because "they only make their money if we improve."...

Paying down debt in exchange for equity, called "recapitalization," is a strong vote of confidence by a private equity (PE) owner. First, since debt holders get paid before equity holders in the event of bankruptcy, it increases risk for the PE firm. Second, it would mean a substantial investment of cash, which is partly what PE firms typically try to minimize by requiring the companies that they own to take on substantial debt in the first place. When PE-owned companies find that they are in danger of being unable to make their debt payments—which both Moody's and S&P Global Ratings have said is currently the case with Blackboard—the PE owners can and do employ a number of different strategies that are financially less risky to them in order to address the problem, either instead of or in addition to recapitalizing.

For example, when Cengage Learning found itself with unmanageable debt levels after its acquisition by private equity, they filed for bankruptcy:

“The decisive actions we are taking today will reduce our debt and improve our capital structure to support our long-term business strategy of transitioning from traditional print models to digital educational and research materials,” Michael Hansen, Cengage Learning’s chief executive, said in a statement.

To be crystal clear, I am not suggesting that Blackboard is likely to file for bankruptcy. Providence Equity has other options at its disposal, some of which I will write about in the next section.

Rather, the point is that Ballhaus' claim that we should just assume Providence will see it as being in their interest to recapitalize Blackboard is not credible on its face to anybody with even passing knowledge of how private equity companies work. For example, the tone of the Washington Business Journal article I referenced above, which (obviously) was written by a business reporter, suggests significant skepticism that Providence will not let the company's debt challenges impact their business decisions. The industry experts we typically consult with when writing financial or business stories like this one were even harsher in their evaluations of Blackboard's position. Two literally laughed out loud at it.

I'm pretty sure that wasn't the coverage Blackboard was hoping for.

And it was destined to get worse. Because they were now stuck in a trap of their own making.

The Trap

What do you do as an analyst when you believe a company has been making misleading statements to you and that there will be evidence supporting your theory of the case in the future? You lay down a marker and wait.

Here's what I wrote:

[I]n fairness, there is an empirical fact of the matter here, and we do not yet have conclusive public evidence that the company's high levels of debt will, in fact, affect their business strategy. So here's what we're going to do:

  1. I will summarize their position as objectively as I can.
  2. I will explain why we don't find their position persuasive.
  3. I will lay out the signs that concrete evidence we will be looking for going forward that will either support or undermine our thesis.
  4. Phil and I will publish updates as we monitor these signs and, if there is no additional public evidence of our thesis by BbWorld 2019 (or strong evidence emerges that we are wrong before then), then we will publish a mea culpa post....

Here are a few actions Blackboard could take in the future that would indicate Providence Equity has chosen to push Blackboard to solve its own debt problem rather than making it go away with more of Providence's money:

  • Sell off one or more parts of the business: A Bloomberg piece written by journalists from their distressed debt desk reports, "With some of Blackboard’s bonds selling at deeply distressed levels, Ballhaus is crafting a comeback, and possible options include the sale of its payment processing division, said the people, who asked not to be identified because the discussions are private." Said payment processing division, Blackboard Transact, is a cash cow for the company. If Blackboard sells off one of its more profitable business units at a time when the company is having trouble making debt payments, that would indicate a choice by Providence Equity to find a way to reduce debt pressure that is less risky for them in terms of cash investment but more risky for Blackboard in terms of long-term health. Particularly since Providence already tried to sell Blackboard once and has now owned the company for well past the normal sell-by date that PE companies like to follow, the sale of Transact might suggest further moves to follow.
  • Unload expenses (like office space): The Washington Business Journal article notes, "Blackboard is also interested in unloading its 70,000 square feet of office space at 1111 19th street, with 12,000 square feet already sublet, according to an April post on Tech Office Spaces. It's unclear where Blackboard will go if it succeeds in leasing out its entire footprint. Blackboard stood to benefit from a tax rebate program for companies that agree to sign 50,000 square feet for at least a dozen years, valued at half the company's tenant improvement costs, or a maximum of $5 million over five years." Of course, companies take cost-cutting measures all the time, regardless of their financial health. The business reporter's phrasing suggests that he may be detecting a whiff of desperation in the specifics of this transaction. Since that's his expertise more than ours, we'll be looking for additional confirmation of our thesis, such as if Blackboard were to...
  • Significantly restructure with major layoffs: If Blackboard were to move to a smaller office while also laying off employees—beyond those that might leave in a sale of a business division or the slow leak of headcount that the company has been having for a while now—that would certainly be an indicator that Providence is not ready to just give Blackboard the money the company needs to complete a turn-around and is instead pushing them to solve their own financial problems.

I wrote that post on July 31st, 2018. Where are we seven and a half months later?

Trap Sprung

Last week, Blackboard announced the sale of Transact.


Note that this is not an objectively bad thing for Blackboard. To the contrary, it helps them with their debt problem in a way that has little to no impact on their core customers. The problem is that it also runs against the grain of the story line that Blackboard executives pushed to us aggressively last summer. They turned what should have been a good story for them into a more complicated story.

Also, last January, Blackboard announced they would be moving their headquarters out of Washington, DC to a new space in Reston, VA.


Note that this is also not an objectively bad thing for Blackboard, also a way for them to manage their debt problem without impacting customers, and also in tension with the story they told us last year.

The layoff evidence is less clear. There are plenty of comments on Glassdoor about ongoing layoffs (as well as voluntary talent drain) at the company, but that sort of evidence needs to be taken with a heaping teaspoon of salt. And honestly, I am hoping that I don't see evidence of a major restructuring going forward. I never want to root for people to lose their jobs.

So overall, there is pretty clear evidence that (a) all the debt agencies were not wrong when they said Blackboard had debt issues, (b) we were not wrong when we said that Blackboard could not expect Providence Equity to solve their problems by simply showering them with more money, and (c) Blackboard is taking necessary and reasonable steps to reduce their debt load. In other breaking news, gravity still exists.

I let Blackboard know I would be writing an update to my previous post and gave Mr. Ballhaus an opportunity to revise and extend his previous remarks. Here's what I got back:

Our decision to divest in Transact is consistent with our strategic efforts to simplify our business as we move to a purely SaaS model and enhance focus on our core teaching and learning portfolio. The fact that we have tightened our strategic focus toward our current education clients and are accelerating innovation to benefit them is a stark contrast from our competitors who are looking to grow their business in areas outside of education.

Proceeds of the sale will go toward deleveraging the company and also present potential opportunities to reinvest in the business.

OK. This isn't a bad statement as far as it goes. The last sentence is most directly relevant. The rest is stuff that he wants to get in, which is fine and expected. The truth is that he's heavily constrained in what he can say about the debt management for legal and other reasons. As I said at the top, regarding the substance of the situation, I'm not a financial expert and do not have access to the information that debt agencies do, so I will wait for them to weigh in on how all of this affects Blackboard's financial prognosis. It can't be bad, but I'm not qualified to judge how much they've improved without the benefit of expert input.

Regarding the PR situation, as far as I'm concerned, this was a fairly normal corporate answer. We're back on terra firma. The more interesting question is how companies can avoid getting themselves into this situation in the first place. Blackboard is far from the only company that has gone through this sort of thing with us. And while we occasionally run into CEOs who are simply bad humans, usually these situations arise out of missteps that happen while the people at these companies are under enormous pressure because the companies are working their way through a rough patch. I have been on the inside of a company as an employee in that sort of a situation. It is not easy. External-facing leaders in particular need to cultivate reflexes to deal with these sorts of crisis situations. And make no mistake; an analyst or reporter raising uncomfortable questions about something your company is struggling with definitely feels like a crisis situation.

So what's the right reflex to cultivate?

Honesty Works

Executives need to understand the power of honesty as an offensive weapon. Set aside ethics for a moment. I'm talking about it from a purely strategic perspective. Let's look at a couple of examples of how to play this card, starting with Blackboard.

I made the analogy earlier between the debt agencies and the Weather Channel. Let's extend that analogy a bit. I live in Massachusetts. It snows a lot up here. (Or at least, it used to.) But we have very professional road crews who know what they are doing. Most of the time, we can get a dumping of 18 inches at night and still drive on safe roads the next morning. We check the weather, but we don't freak out about it. One way Mr. Ballhaus could have handled the debt conversation would have been to wait for us to bring the topic up—which we would have—and then say something analogous to the following:

It's true; the Weather Channel is predicting snow. I lived for ten years in rural Minnesota. In a house with a very long driveway. I have a truck with a snow plow on it. Here is my shovel. Any questions?

Here's how that looks in business terms:

It's true; the debt agencies are concerned about our debt load. That's one reason why Providence Equity brought me in. I'm a Private Equity turn-around guy. This is pretty much what I do. You guys have been around the block enough to know that I can't talk about the details of how we're going to manage it, but we have strategies in place for strengthening the company's balance sheet while protecting our customers.

Every word of this is either undeniably true or reasonably plausible, and there's not much we could have said in response. It also doesn't make for much of a story. It becomes a "this is one of a number of factors that we're watching" kind of thing. It doesn't become the dominant story line coming out of BbWorld. And it softens the analysts up just a little bit. With a story like debt risk, there's always a lot that we don't know. The flavor of our coverage is influenced by our trust in management to be reasonably honest and open with us. In this context, a little bit of good will goes a long way.

For another example, take the case where Pearson was trying to manage a story I was chasing of their CIO's penchant for repeatedly talking about the company's supposed ambition to build, in his words, the Netflix of education. I was (and still am) pretty sure that isn't what Pearson is trying to do. But because this very high-level person continues to be allowed to publicly declare that they are trying to do this, and because Pearson is a big place where the right hand sometimes doesn't know what the left hand is doing, only somebody who outranks the CIO can definitively put the question to rest. And there is only one person who outranks him: CEO John Fallon. After much discussion with Pearson's PR team and some interviews with a couple of the CIO's peers in other relevant parts of the organization, and very much to my surprise, I was given direct access to Pearson's CEO. So here we go, I thought. This was going to be easy. He could put this story to bed, and I could spend my time writing a story about something good rather than something dumb.

That's not what happened. 

But it so easily could have.

Yeah, Pearson doesn't want to be the Netflix of education, and Albert shouldn't have said that we do. We do think that we need to become an internet-scale digital company, and we do think that the trend toward renting digital assets is one that is relevant to the educational market. That said, we understand that analogies are fraught in education and we don't wish to oversimplify. In fact, we sold off our consumer businesses in part because we want supporting educators in managing those complexities to be the core of what we do. When we talk about efficacy, that's what we mean.

That answer not only would have spiked the "Pearson can't stop talking about being the Netflix of education" story; it also would have turned me toward writing an update to my original efficacy story, complete with reporting on the genuinely good work the company's efficacy team has been doing since then. The Netflix thing would have ended up getting mostly buried as a side note about how difficult and fraught it is for companies to talk about their work.

It wouldn't have mattered if I knew the answer was a strategic attempt to kill or divert the story. As long as it was honest, it would have been fair game. Beyond that, I would much rather write a story about a company that's trying to do the right thing and does it imperfectly than play a game of gotcha with a company because the management is giving answers that I feel I have an obligation to police. When leadership chooses not to play the honesty card, they often accidentally trigger a gotcha game that generally doesn't end well for them and puts them in a worse light than they actually deserve. I wanted to say definitively that Pearson isn't trying to be the Netflix of education because I believe it to be true. I know they are doing good work because I have seen it with my own eyes. I could have written a story about that. But because Mr. Fallon chose not to play the honesty card, the story ended up being about Pearson failing to clearly disavow the Netflix analogy, and I couldn't definitively write what I believe to be true about the company because Mr. Fallon didn't give me the proof that I needed for the story.

I could go on; I have many more examples like these. A positive one is when Instructure's former CEO Josh Coates completely transformed a negative story about the company charging customers for access to their own data. Not only did he admit that the company screwed up in very blunt terms; he changed the policy, encouraged us to call customers and verify that they were satisfied with the changes, and thanked Phil for calling his attention to the problem. There are reasons why we wrote very little negative coverage of Instructure during the Coates years. One is that the leadership team really understood the power of honesty.

The bottom line is that honesty is disarming. Good analysts always try to maintain healthy skepticism, but they also try to be good judges of character. Because good analysis is partly based on knowing how much you trust the particular version of events that a company's management is giving you. In contrast, when leaders give in to the (understandable) temptation to deflect, they look dishonest. I want to be very clear about separating a moment of failing to be honest, which we all have had under pressure from time to time, from being a fundamentally dishonest person, of which I have met relatively few in my life. Analysts (and reporters) have to distinguish between the two based on very little information, and they have the obligation to be skeptical. Also, good analysts have instincts that lead them to poke where it hurts. The reflex of the person being poked will be to protect the sore spot. Effective leaders learn to fight that reflex in the moment. They acknowledge problems that the analyst may have uncovered (to the degree that they can) and turn that moment of vulnerability into an opportunity.

The post A Blackboard Debt Update, and a Lesson on Public Relations appeared first on e-Literate.

by Michael Feldstein at March 13, 2019 07:52 PM

Apereo Foundation

How to Procure Open Source

How to Procure Open Source

A special blog post by Apereo Board Member Anne-Marie Scott.

"As part of my work as a Board member of the Apereo Foundation, we’ve been working on new content to more clearly make the case for adopting open source, particularly in education. Alongside that we’ve been working on developing open source health measures that will give transparency about how a project is operating, and help support institutional decisions about adoption."

by Michelle Hall at March 13, 2019 07:23 PM

March 11, 2019

Michael Feldstein

Instructure: Plans to expand beyond Canvas LMS into machine learning and AI

It's common knowledge that Instructure has shifted its focus to place more emphasis on its growth in corporate learning markets than in the educational markets that have fueled the company growth to date. We covered the initial news about their introduction of the corporate learning LMS, Bridge, four years ago.

While Instructure has excelled on maintaining product focus and simplicity of user experience, this move outside of education raises the question about whether they can maintain company focus. The corporate market is very different than the education market - different product needs, fragmented vendor market, different buying patterns. Many companies have tried to cross over between education and corporate learning, but most have failed. Blackboard, D2L and Moodle have made a footprint in the corporate space using one product for both markets. Instructure's approach is different.

As noted, the other Big Four LMS vendors are also targeting corporate learning (or professional ed, or workplace, pick your name). D2L and Blackboard are using the same platforms in both markets (Brightspace for D2L, Learn and Open LMS for Blackboard), while Moodle released Workplace, a set of plugins on top of core Moodle. Instructure, however, has different products for educational and corporate markets.

That is old news. What is more interesting is to understand Instructure's emerging strategy given the new executive team. Thanks to the nature of Instructure being a publicly-traded company, we are getting more insight that should set expectations for educational customers. As CEO Dan Goldsmith said during an investor conference a week ago:

We really changed the company, as I came in nine months ago and then took over as CEO January 1st of this year. We're initiating the second chapter in the journey of Instructure.

I should first note that the audience for these calls is the investment community, so naturally Instructure executives focused more on financial performance and projections that they would in academic meetings. But there is a lot to learn here.

In some ways, the changes to operations of Instructure are welcome and are already helping them manage corporate finances. In other ways, however, that second chapter reads a lot like Blackboard. Moving beyond the LMS, willing to bet on corporate acquisition, expecting big focus on data and analytics, and continuing challenges in completing products.

Operational Improvements

One of the ongoing criticisms of Instructure, particularly by their competitors, is that they continue to lose money and are buying growth. While these observations are accurate, as long as Instructure keeps growing, they have never been at risk of running out of money or having their losses significantly impact their operations. Under the new leadership, Instructure has been much more aggressive in managing expenses, with a big milestone described on the conference call by CFO Steve Kaminsky [emphasis added].

Turning to the expense side. With our focus on operational excellence during the second half of 2018, we've changed the mindset of our leadership team and the entire organization about how we approach the business and fund investment. We focused on disciplined investments for balancing profitable growth has been put in place and is reflected in the outlook we provided today. On the cash side, we have a strong cash position to support our important strategic objectives for both Canvas and Bridge. And looking forward to 2019, we anticipate being approximately free cash flow neutral for the full year.

Beyond simple finances, we have seen some operational changes for international operations as well. The global regions (EMEA, Latin America, APAC) all have more autonomy now, including control over country-specific marketing and product management. The non-US operations have moved beyond being regional sales and support offices into more aggressive engines of growth. In Europe and other regions, the management team has more autonomy is deciding which countries are worth investment for expanding markets, and when. From the Feb 25th investor presentation:

The Instructure Story

With the improving operations, Instructure has reduced their operating losses from 57% of revenue to 10% of revenue in the past three years.

Investor conference slide

Moving Beyond the LMS

On the same day as Instructure's earnings call and release of FY2018 financial results, the company announced the acquisition of Portfolium for $43 million, a small startup focusing on "ePortfolio network, student-centered assessment, job matching capabilities, and academic and co-curricular pathways". We interviewed Instructure staff the same day as the earnings call and noted a different message. In our initial call, the Portfolium acquisition was positioned primarily as a way to improve how Instructure can handle structured assessments in the education market - think CBE, mastery learning, with ePortfolios not as the goal but as the necessary infrastructure. During the earnings call, however, the positioning was more about bridging educational and corporate markets and expanding total addressable market (TAM).

Today, we've taken a great stride towards enabling that transition with our expected acquisition of Portfolium, a successful long time Canvas partner. Portfolium vision is to help each person realize their full potential by connecting learning with opportunity, through e-portfolios, program and course level assessments, career pathways and by matching students to job opportunities. Portfolium will join Instructure with a wealth of shared customers, such as Virginia Tech, Santa Clara University and Swinburne University in Australia. This acquisition is a great match in vision and culture and represents our first major step into the Student Success market. And while Portfolium's current offerings provide an excellent solution, more importantly, they establish the first Bridge between academia and the corporate world that aligns precisely with Instructure’s vision.

Instructure now views itself as a company with a suite of products, and they are much more open to using corporate M&A to build this portfolio.

Emphasis on Data & Analytics

The second initiative announced on the earnings call was DIG, a strategic move with data and analytics.

I am also pleased to share with you an early insight into our second growth initiative focused on analytics, data science and artificial intelligence. The code name for this initiative is DIG. And this technology platform combined with the most comprehensive SaaS database on the educational experience uniquely positions us to deliver meaningful value to our customers. And from a growth perspective, DIG has the potential to double our TAM in education.

Instructure started ramping up their data and analytics efforts (again) about a year ago, although the focus was described at the time as being about internal analytics - that is, making Canvas a better and more valuable LMS product. From what I have heard the product validation for DIG are consistent with this message - dashboards, surfacing useful data within a workflow, etc. But that was not how DIG is being sold during the conference call [emphasis added].

We've been working on the scaffolding for [DIG] for well over a year now. I mentioned in our remarks that we already have product validation towards out there in the market. We have instructors and students consuming output from some of the initial experiments with DIG. And we anticipate later this year obviously to make more announcements around specific products and offerings and how we bring them into the market. DIG ultimately is a platform first and foremost based upon machine learning and artificial intelligence. I believe that any multi tenant SaaS company born in the cloud has the opportunity once they hit a certain market share. And in fact, it may even be incumbent upon those organizations to partner with the industry and evolve that industry with new insights and predictive modeling using AI and ML. That's what DIG is at its heart.

This is brand new behavior for Instructure as a company. Previously the company was reticent to talk much about non-released products, but now they are talking not just about a new initiative, they are touting buzzwordy machine learning and artificial intelligence and predictive modeling well before any of those capabilities exist or are in customer hands. Goldsmith further clarified the DIG plans during the investor conference discussion [starting at 9:00, emphasis added].

We already have analytical capabilities in our Canvas platform. I want to be really clear and delineate the difference between an analytics and reporting capability, and a machine learning and AI platform. [snip]

We have the most comprehensive database on the educational experience in the globe. So given that information that we have, no one else has those data assets at their fingertips to be able to develop those algorithms and predictive models.

Goldsmith then described an example of predicting a student's expected performance in a class and how that prediction reliability goes up over time. Then we get the vision.

What's even more interesting and compelling is that we can take that information, correlate it across all sorts of universities, curricula, etc, and we can start making recommendations and suggestions to the student or instructor in how they can be more successful. Watch this video, read this passage, do problems 17-34 in this textbook, spend an extra two hours on this or that. When we drive student success, we impact things like retention, we impact the productivity of the teachers, and it's a huge opportunity. That's just one small example.

Our DIG initiative, it is first and foremost a platform for ML and AI, and we will deliver and monetize it by offering different functional domains of predictive algorithms and insights. Maybe things like student success, retention, coaching and advising, career pathing, as well as a number of the other metrics that will help improve the value of an institution or connectivity across institutions. [snip]

We've gone through enough cycles thus far to have demonstrable results around improving outcomes with students and improving student success. [snip] I hope to have something at least in beta by the end of this year.

Wow. Robot tutor in the sky - meet the new kid on the block.

The most generous interpretation I have is that they are being sloppy in their terminology and casually throwing out machine learning and AI to eager investors, while the reality could be more mundane but useful sharing of useful data to help instructors or administrators.

If I had to guess, however, I would suggest that Instructure has its sights set on additional corporate acquisitions over the next year or two to try and back up these expectations. I hope they realize they are not the first company to believe that AI on top of their best-in-world data will deliver success for all.

The message is also clear that Portfolium and DIG are intended to increase TAM. This means separate product categories with separate pricing in addition to Canvas. Either that or offering Canvas at different pricing levels to include add-on product bundles.

Challenges in Completing Products

We noted the modernization efforts behind Quizzes.Next, the next generation quizzing and test engine for Canvas, as well as the big schedule miss. In short, Quizzes.Next was announced at InstructureCon 2016 as being available within a few months. 12 months later at InstructureCon 2017 it entered limited beta, and at InstructureCon 2018 it entered general availability. But the story is not over. Quizzes.Next is still not at feature parity with the original quiz engine, as noted by Indiana University.

Instructure has released a new quizzing tool for Canvas called Quizzes.Next. Quizzes.Next offers several new features and question types, but is missing many features from the current Quizzes tool on which many instructors depend. Both tools will continue to be available until Quizzes.Next has achieved feature parity with Canvas Quizzes. The original Canvas Quizzes tool will eventually be retired, but Instructure has not yet announced the timeline.

If you read the Canvas Community page comparing features, it is clear that feature parity is not imminent. The transparency is impressive, however, and from what we are hearing customers are still giving Instructure some leeway because of trust. But Quizzes.Next and its delivery is a continuing problem, not least of which is the reduction in R&D spending growth for Canvas, described by CFO Steve Kaminsky on the call.

Regarding the R&D investment, we don't really break that out. But what we can tell you qualitatively is while we are doing some incremental investments on the Canvas side and DIG is a good example of that, the lion share of the growth in R&D is going into Bridge.

What to Expect

Instructure is at a crossroads. While they continue to grow, especially in education markets, and while they report improving financial performance, Instructure is entering uncharted territory (for them) in this second chapter. It is remarkable that they have not lost a major educational LMS customer in the 8+ years since Canvas was first selected by the Utah Education Network, but there are some warning signs that should not be ignored and some risky expectations being set.

The post Instructure: Plans to expand beyond Canvas LMS into machine learning and AI appeared first on e-Literate.

by Phil Hill at March 11, 2019 11:16 PM

March 08, 2019

Dr. Chuck

Tsugi Achieves LTI Advantage Certification

Tsugi ( is one of the first learning tools to achieve a brand-new certification for an interoperability standard called LTI Advantage, continuing the longtime leadership of open source learning projects in the Apereo Foundation ( in standards and interoperability.   Tsugi is an application library that allows rapid development of standards-compliant learning applications.

Tsugi certification coupled with the recent Sakai certification completes an open source end-to-end solution for both the Platform and Tool versions of the LTI Advantage specification.  Open Source implementations allow proprietary vendors to examine source code and have an endpoint for regular interoperability testing.

Apereo projects like Tsugi and Sakai benefit the entire marketplace whether or not a school adopts the software that is produced as part of Apereo.   – Charles Severance, Founder Sakai and Tsugi Projects

The Tsugi project provides a free test server that allows LMS vendors like Sakai, Blackboard, Canvas and Desire2Learn to do regular LTI Advantage interoperability testing with a scalable production LTI Advantage compliant educational application store.

In addition to using LTI Advantage for integration into enterprise LMS systems, Tsugi tools also can be integrated into Google Classroom.

For more information or to see how to use Tsugi to develop standards compliant learning tools see

by Charles Severance at March 08, 2019 02:41 PM

March 07, 2019

Michael Feldstein

Flawed AEI Report on Online Education: The good, the bad, and the ugly

To paraphrase the intro paragraph from January's post on the George Mason University report, another year month and another deeply flawed report about online education in US higher education, this time by Di Xu (assistant professor of educational policy and social context at the University of California
Irvine and a visiting fellow at AEI) and Ying Xu (Ph.D. candidate at the School of Education at the University of California Irvine). The report is titled "The promises and limits of online higher education: Understanding how distance education affects access, cost, and quality".

AEI Report Cover

While the supply and demand for online higher education is rapidly expanding, questions remain regarding its potential impact on increasing access, reducing costs, and improving student outcomes. Does online education enhance access to higher education among students who would not otherwise enroll in college? Can online courses create savings for students by reducing funding constraints on postsecondary institutions? Will technological innovations improve the quality of online education?

This report finds that, to varying degrees, online education can benefit some student populations. However, important caveats and trade-offs remain.

In many ways this report takes a similar approach to the GMU report and a prior one by Caroline Hoxby from Stanford University, which was subsequently withdrawn, in asking important questions but providing flawed analysis to support conclusions. The problems with the American Enterprise Institute (AEI) report lie in its description of the history of online education and the 50 percent rule, the usage of data to describe the "supply side" of online, and some misinterpretations of IPEDS data. The flaws are hard to overlook, which is a shame, in that much of the qualitative discussion on online education provides a nuanced set of answers to the questions posed above.

The Good

The AEI report takes a look at a little-used portion of the IPEDS data set - The Completions survey and its program-level data on whether an institution offers certain programs at all and whether they are offered as a fully online (distance education) offering. This data has its flaws, which we'll get to below, but it was quite interesting to get a summary view at the program level.

program-level AEI summary of IPEDS data for online

After a relatively solid discussion of research findings on Online Education and Student Outcomes, which summarizes positive and negative results along with the context and limitations of the relevant research, the report presents its discussion of known strategies to improve online education. This is a welcome relief, as many studies view online as a conclusion to be made about online vs. face-to-face, while this one summarizes known methods to continue improvements of a necessary modality.

Based on the growing knowledge regarding the specific challenges of online learning and possible course design features that could better support students, several potential strategies have emerged to promote student learning in semester-long online courses. The teaching and learning literature has a much longer list of recommended instructional practices. However, research on improving online learning focuses on practices that are particularly relevant in virtual learning environments. These include strategic course offering, student counseling, interpersonal interaction, warning and monitoring, and the professional development of faculty.

The Bad

The introduction relies heavily on the "50 percent rule" and 1998 and 2006 changes to this rule as key points in the expansion of online education. This regulation did have an effect, but so did a number of other factors not mentioned in the report. To make matters worse, the wording of the rule conflates students and institutions. For example, in an email conversation with Russ Poulin from WCET, he noted how the following is inaccurate:

Sim­ilarly, the HEA also denied access to certain types of federal financial aid and loans for students who took more than half their courses through distance courses.

yet this statement is accurate:

…the rule dictated that institutions that offered more than 50 percent of their courses through distance edu­cation or enrolled more than half of their students in distance education courses would not be eligible for federal student aid programs.

The regulation applied to institutions and in no way measured this usage at the student level. I find that this article from New America does a much better job describing this regulation's history and impact.

Update 3/8: Poulin also noted (see comment below):

After talking to you Phil, the oddity of the 50% discussion being front and center hit me even more. The lifting of the 50% rule had an impact on only a small number of institutions. Several for-profits and a small number of non-profit and public universities. The vast growth in distance learning has primarily been in institutions that get nowhere near the 50% mark, so the change in that rule was not a direct influence in their decision to enter the distance education market. To place it front and center seemed odd to me and not a real reflection of the motivations for most college leaders.

The report also confuses institutional vs. student level data in looking at per-state online statistics.

Finally, considering that state-level policies may shape online learning in unique ways, Figure 13 shows online enrollment by state in the 2016–17 school year. Unsurprisingly, the most populated states, such as California, Florida, and Texas, also had the largest number of online course takers. Once accounting for between-state differences in overall higher education enrollment, four states have the largest share of students who enrolled in at least one online course in 2016: Arizona (61 percent), Idaho (52 percent), New Hampshire (58 percent), and West Virginia
57 percent).

This might be nitpicking, but the IPEDS data referenced is for institutions located in each state, not students located in each state. But a report trying to make sense of a complex subject should get this information correct and not add to the confusion.

The Ugly

The worst aspects of the report can be seen in figure 1 and an attempt to summarize changes in the supply side of online education. The authors chose to define the supply side as number of institutions offering at least one online course or one online program, using the aforementioned Completions / program-level data.

AEI analysis of IPEDS dataI'll wait while you take the necessary 5 minutes to decipher the worst color-legend usage in a chart that I've seen in years . . . Not yet? . . .

When I shared this image on Twitter, Kevin Carey pointed out some results that seems non-sensical.

The GMU report and the Stanford / Hoxby report made the more common mistake of essentially conflating online education with the for-profit sector, but this data makes little sense on the surface - implying that the for-profit sector offers relatively few online programs compared to public and private institutions. Looking at our 2016 IPEDS profile, you can see that 4-year for-profits by far have the greatest percentage of students in fully online programs (69%). How does AEI measure for-profits as much lower in offering fully-online programs?

IPEDS 2016 data

It took a while to figure out, but I think the authors made two mistakes. One is that they combined all for-profits together (2-year and 4-year), which is confusing since 2-year for-profits have the lowest usage of online education and a bunch of really small schools. This combination cuts the for-profit numbers dramatically. Look at the 2012 summary data below, where I show data for each sector and then combining 2-year and 4-year sectors together for public, private, and for-profit.

The second issue is that simply measuring for-profits by institution using Completions program-level data is an unreliable approach to understanding online education supply, particularly for the for-profit sectors. Most for-profit systems own a number of smaller campuses, each with their own IPEDS code, yet the online programs are offered centrally by the system. And the Completions survey DE data has major holes in it. Consider South University (part of EDMC as of the 2012 data shown below):

All 21 online programs are offered through the online campus, with over 12,364 taking exclusively DE courses and 8,898 taking no DE courses. Using the AEI methodology, 13 of the 14 institutions have no online courses or programs - almost no supply of online education in their language.

Also consider DeVry University, which does not list a centralized online campus yet has significant online presence. For whatever reason, they report the student enrollment data per campus, but they did not fill out the Completions program-level data at all. Zero supply of online education in AEI's approach.

My therapists jumped in at this point and convinced me to not fully duplicate the AEI findings (serenity now!!!). What's important here is that the basis of AEI's description of online education supply, using institutional metrics that are dubious and ignore how the for-profit sector works, is flawed and misleading. Technically they used data in IPEDS, but they misunderstood its usage and limitations.

Yes, there are valuable parts of this report. But like the GMU and Stanford reports, the flaws in analysis make it very difficult to separate the good from the bad and the ugly. This type of report from well-funded organizations aimed at policy-makers should inform, not confuse, but yet again we are faced with some serious flaws. We need better.

The post Flawed AEI Report on Online Education: The good, the bad, and the ugly appeared first on e-Literate.

by Phil Hill at March 07, 2019 10:39 PM

Adam Marshall

WebLearn User Group: Tues 12 March 14:00-16:00

Please join us at the next meeting of the WebLearn User Group:

Date: Tuesday 12 March 2019

Time: 2:00 – 4:00 pm, followed by refreshments

Venue: IT Services, 13 Banbury Rd

Come and meet with fellow WebLearn users and members of the Technology Enhanced Learning (TEL) team to give feedback and share ideas and practices.

Book now to secure your place.


  • Canvas@Oxford project team: Update on the Canvas rollout to Year 1 programmes of study
  • James Shaw, Bodleian Libraries: Copyright and the CLA: Preparing digital material for presentation in a VLE
  • Jon Mason, Medical Sciences: Interactive copyright picker (based on source and intended use)
  • TEL team: Design and content for WebLearn pages
  • Adam Marshall: WebLearn updates

Join the WebLearn User Group site: for regular updates and access to audio recordings of previous presentations.

Dr Jill Fresen, Senior Learning Technologist, Technology-Enhanced Learning, IT Services, University of Oxford

by Adam Marshall at March 07, 2019 02:41 PM

February 24, 2019

Dr. Chuck

Abstract: Coursera Office Hours @ Pengucon – Python for Everybody

This is a meeting between students of Dr. Chuck’s Python for Everybody, Internet History, Technology, and Security, and Web Applications for Everybody (PHP / SQL) online Coursera courses and anyone else who is interested in MOOCs and the MOOC movement.  You can see other meetings that Dr. Chuck has had with students at

by Charles Severance at February 24, 2019 05:54 PM

February 13, 2019

Dr. Chuck

What Should I do After I Finish the Python for Everybody Specialization?

I got this message from a student:
I am currently a student in your Python for Everybody online Coursera specialization, and am about to complete the Capstone course. I would like to move my career into App Development / Software Engineering management, what is the next course that you would recommend that I take?
Here is my answer.

Congratulations on making it through the specialization. In terms of what to do next – a lot has to do with how confident you feel at this point. If you are still struggling with the programs in the specialization – then you might want to go back and take another “beginner class” – there are levels of beginner classes and you might benefit from one that is more rigorous like this one from UMich:

If you are confident in your programming skills, it depends on what you want to do. If building web apps is something you find interesting, these specializations will move you in that direction:

If you want to go into Data Mining – we have a specialization for that too:

You should have your programming skills well in place before you take the data science specialization – but it has a lot of good stuff and important job-ready skills.

by Charles Severance at February 13, 2019 01:51 AM

February 12, 2019


Peer Assessment – Reflect and Improve

Peer assessment or review can improve student learning, and there's a way to do it in a course site.


by Dave E. at February 12, 2019 04:17 PM

February 08, 2019

Adam Marshall

Copyright and Audio-Visual Material

I thought this copyright guidance from LearningOnScreen (The British Universities and Colleges Film and Video Council) may be of interest to some.

by Adam Marshall at February 08, 2019 04:42 PM

January 28, 2019

Adam Marshall

Free Accessibility Tool


I thought I’d pass along the following message from JISC.

It is important to ensure that the visual content of your website and learning resources has alternative text for those who either cannot see the visual content or struggle to make sense of its interpretation.

However, how do you know what is an appropriate description? And some visual content is merely eye candy and is best hidden entirely from screenreader users rather than wasting their time announcing something that is meaningless to the learning experience.

Making this different choices requires a certain degree of understanding but the good news is that there are some excellent free training resources out there. A recent quote from a Vision Australia newsletter reminded me of the Poet training Tool (which I’ve used  – and it has nothing to do with poetry!).

Vision Australia’s partner, Benetech has provided an initiative called Poet Training Tool which provides best practice guidelines and exercises that will help you grow your skills in writing effective image descriptions benefiting everyone who needs to access your digital documents, web pages and mobile apps.

This free resource is broken up into 3 helpful sections:

  1. Helps you determine when a description is actually needed.
  2. Provides guidelines on how to write an effective description (with examples).
  3. Upload content and practice writing your own descriptions.

If you or your colleagues are going to be involved in revisiting digital images on your website or learning platform then I highly recommend using these resources.

Alistair McNaught
Subject specialist – accessibility

by Adam Marshall at January 28, 2019 03:21 PM

November 23, 2018

Matthew Buckett

Firewalling IPs on macOS

I needed to selectively block some IPs from macOS and this is how I did it. First create a new anchor for the rules to go in. The file to create is:/etc/pf.anchors/org.user.block.out and it should contain:

table <blocked-hosts> persist
block in quick from <blocked-hosts>

Then edit: /etc/pf.conf and append the lines:

anchor "org.user.block.out"
load anchor "org.user.block.out" from "/etc/pf.anchors/org.user.block.out"

Then to reload the firewalling rules run:

$ sudo pfctl -f /etc/pf.conf

and if you haven't got pf enabled you also need to enable it with:

$ sudo pfctl -e

Then you can manage the blocked IPs with these commands:

# Block some IPs
$ sudo pfctl -a org.user.block.out -t blocked-hosts -T add
# Remove all the blocked IPs
$ sudo pfctl -a org.user.block.out -t blocked-hosts -T flush
# Remove a single IP
$ sudo pfctl -a org.user.block.out -t blocked-hosts -T delete

by Matthew Buckett ( at November 23, 2018 12:41 PM

November 09, 2018

Apereo OAE

Apereo OAE Snowy Owl is now available!

The latest version of Apereo's Open Academic Environment (OAE) project has just been released! Version 15.0.0 is codenamed Snowy Owl and it includes some changes (mostly under the hood) in order to pave the way for what's to come. Read the full changelog at Github

Image taken from bird eden.

November 09, 2018 06:50 PM

September 27, 2018

Sakai Project

Sakai 12.4 maintenance is released!

Dear Community,

I'm pleased to announce on behalf of the worldwide community that Sakai 12.4 is released and available for downloading! 

Sakai 12.4 has 88 improvements including: 

  • 22 fixes in Assignments
  • 14 fixes in Gradebook
  • 9 fixes in Tests & Quizzes (Samigo)
  • 7 fixes in Lessons
  • 6 fixes in Roster
  • 5 fixes in Portal

For more information, visit 12.4 Fixes by Tool

by WHodges at September 27, 2018 06:11 PM

August 15, 2018

Sakai Project

Now Open! Call for Proposals for the Sakai Virtual Conference 2018

Sakai Project Logo

We are actively seeking presenters who are knowledgeable about teaching with Sakai. You don’t need to be a technical expert to share your experiences! Submit your proposal today! The deadline for submissions is September 21st, 2018.

Save the Date: The Sakai Virtual Conference will take place entirely online on Wednesday, November 7th.

by MHall at August 15, 2018 06:58 PM

August 13, 2018

Sakai Project

Sakai Community Survey - Number of Users at Your Institution

We would like your help in tallying up the total number of Sakai users worldwide.

by MHall at August 13, 2018 04:33 PM

July 04, 2018


F2F Course Site Content Import

If you're tasked with teaching an upcoming course that you've taught in the past with the University - there's no need to rebuild everything from scratch - unless you want to. Faculty teaching face to face (F2F) courses can benefit from the course content import process in Site Info. This process allows you to pull … Continue reading F2F Course Site Content Import

by Dave E. at July 04, 2018 06:56 PM

June 11, 2018

Apereo OAE

Strategic re-positioning: OAE in the world of NGDLE

The experience of the Open Academic Environment Project (OAE) forms a significant practical contribution to the emerging vision of the ‘Next Generation Digital Learning Environment’, or NGDLE. Specifically, OAE contributes core collaboration tools and services that can be used in the context of a class, of a formal or informal group outside a class, and indeed of such a group outside an institution. This set of tools and services leverages academic infrastructure, such as Access Management Federations, or widely used commercial infrastructure for authentication, open APIs for popular third-party software (e.g. video conference) and open standards such as LTI and xAPI.

Beyond the LMS/VLE

OAE is widely used by staff in French higher education in the context of research and other inter-institutional collaboration. The project is now examining future directions which bring OAE closer to students – and to learning. This is driven by a groundswell among learners. There is strong anecdotal evidence that students in France are chafing at the constraints of the LMS/VLE. They are beginning to use social media – not necessarily with adequate data or other safeguards – to overcome the perceived limitations of the LMS/VLE. The core functionality of OAE – people forming groups to collaborate around content – provides a means of circumventing the LMS’s limitations without selling one’s soul – or one’s data – to the social media giants. OAE embodies key capabilities supporting social and unstructured learning, and indeed could be adapted and configured as a ‘student owned environment’: a safe space for sharing and discussion of ideas leading to organic group activities. The desires and requirements of students have not featured strongly in NGDLE conversations to this point: The OAE project, beginning with work in France, will explore student discontent with the LMS, and seek to work together with LMS solution providers and software communities to provide a richer and more engaging experience for learners.

Integration points and data flows

OAE has three principal objectives in this area:

  1. OAE has a basic (uncertified) implementation of the IMSGlobal Learning Tools Interoperability specification. This will be enriched to further effect integration with the LMS/VLE where it is required. OAE will not assume such integration is required without evidence. It will not drive such integration on the basis of technical feasibility, but by needs expressed by learners and educators.
  2. Driven by the significant growth of usage of the Karuta ePortfolio software in France, OAE will explore how student-selected evidence of competency can easily be provided for Karuta, and what other connections might be required or desirable between the two systems.
  3. Given the growth of interest in learning analytics in France and globally, OAE will become an exemplary emitter of learning analytics data and will act wherever possible to analyse each new or old feature from a designed analytics perspective. Learning analytics data will flow from learning designs embedded in OAE, not simply be the accidental output that constitutes a technical log file.

OAE is continuing to develop and transform its sustainability model. The change is essentially from a model based primarily on financially-based contributions to that of a mixed mode community-based model, where financial contributions are encouraged alongside individual, institutional and organisational volunteered contributions of code, documentation and other non-code artefacts. There are two preconditions for accomplishing this. The first, which applies specifically to code, is clearing a layer of technical debt in order to more easily encourage and facilitate contributions around modern software frameworks and tools. OAE is committed to paying down this debt and encouraging contributions from developers outside the project.

The second is both more complex and more straightforward; straightforward to describe, but complex to realise. Put simply, answers to questions around wasteful duplication of resources in deploying software in education have fallen out of balance with reality. The pendulum has swung from “local” through “cloud first” to “cloud only”. Innovation around learning, which by its very nature often begins locally, is often stifled by the industrial-style massification of ‘the hosted LMS’ which emphasises conformity with a single model. As a result of this strategy, institutions have switched from software development and maintenance to contract management. In many cases, this means that they have tended to swap creative, problem-solving capability for an administrative capability. It is almost as though e-learning has entered a “Fordist” phase, with only the green shoots of LTI enabled niche applications and individual institutional initiatives providing hope of a rather more postmodern – and flexible - future.

OAE retains its desire and ambition to provide a scalable solution that remains “cloud ready”. The project believes, however, that the future is federated. Patchworks of juridical and legal frameworks across national and regional boundaries alone – particularly around privacy - should drive a reconsideration of “cloud only” as a strategy for institutions with global appetites. Institutions with such appetites – and there are few now which do not have them – will distribute, federate and firewall systems to work around legislative roadblocks, bumps in the road, and brick walls. OAE will, then, begin to consider and work on inter-host federation of content and other services. This will, of necessity, begin small. It will, however, remain the principled grit in the strategic oyster. As more partners join the project, OAE will start designing a federation architectural layer that will lay the foundation to a scenario where OAE instances dynamically exchange data among themselves in a seamless and efficient way according to a variety of use cases.

ID 22-MAY-18 Amended 23-MAY-18

June 11, 2018 12:00 PM