The University of Toronto Settlement Is a Turning Point for Academic Integrity in Canada

May 22, 2026

On April 1, 2026, Justice Meaghan M. Conroy of the Federal Court of Canada issued a consent judgment confirming that the Easy EDU tutoring companies infringed the copyright of the University of Toronto and three named professors: Robert Gazzale, Lisa Kramer, and Ai Taniguchi. Joe Friesen covered the story for The Globe and Mail (paywalled, but worth tracking down). The settlement requires Easy EDU to pay $1 million in damages, plus HST and interest. A counterclaim by Easy EDU against the university was dismissed without costs. The case had been before the courts since 2022.

Friesen reported that Easy EDU reproduced course outlines, slide presentations, lecture notes, and assignments without authorization. In some instances, the company provided tests written by faculty with answers included, placing students at direct risk of academic misconduct violations. One published adjudication described how 180 students received a study package containing 22 questions that corresponded directly to questions a professor had written for an assessment. The student named in that case received a grade of zero and a 28-month suspension.

This case matters beyond copyright law and anyone who works in academic integrity in Canada should be paying attention Why? Because the case could set a precedent for how Canadian institutions respond when students use file-sharing services, term paper mills, or engage so-called academic consultants.

What the Settlement Exposes

Let’s be clear: the Easy EDU case did not emerge in isolation. The case reflects a pattern I and others have documented extensively. In Academic Integrity in Canada: An Enduring and Essential Challenge, which Julia Christensen Hughes and I edited and published with Springer in 2022, our contributors wrote about contract cheating in Canada in a number of chapters. Collectively, we traced the commercialization of academic support services as part of a broader commodification of higher education. The volume includes chapters on contract cheating in Canada and on EdTech-enabled contract cheating, both of which point to the same structural condition that made Easy EDU possible: a market for services that operates in parallel to formal education, targeting students under pressure, with few regulatory constraints.

Canada has no legislation against contract cheating companies. The U of T settlement is a copyright remedy, not a criminal one. Easy EDU was not shut down because what it did was illegal under a contract cheating statute. It was held responsible for reproducing materials that belonged to the university and its faculty. This distinction is important here because copyright law filled a gap that academic integrity policy could not. 

The Platformization of Academic Misconduct 

A recent 2026 study published in the British Educational Research Journal adds another dimension to this picture. My PhD student Gengyan Tang led this study, with Wei Cai and me as co-authors. Tang, Cai, and I examined commercial academic misconduct appeal services operating in China’s digital marketplace and found that these agencies target Chinese international students through platforms such as Xiaohongshu (RED). These services operate in a regulatory and ethical grey zone, packaging appeal support as a marketable product and translating case outcomes into metrics like success rates.

Tang, Cai, and I conceptualize this process as self-platformization: commercial actors reorganizing educational assistance in alignment with platform economies. The same logic applies to tutoring services like Easy EDU. These are not tutoring companies in any traditional sense. They are platform-aware businesses that use algorithms, social media, and scale to insert themselves into students’ academic lives at precisely the moments when students are most vulnerable.

The students in the U of T case were not, for the most part, bad actors. Many were international students navigating unfamiliar institutional systems, in some cases at risk of losing their study permits. Easy EDU identified that vulnerability and built a business model around it. One student, identified only by initials in the published adjudication, faced a 28-month suspension, not because they set out to deceive, but because a commercial service supplied unauthorized materials and they used them.

In our study, Tang, Cai, and I argue that institutions have invested heavily in prevention and detection but have largely ignored the post-violation stage. That gap is where commercial services can operate with relative ease because there is nothing stopping them from doing so. Universities focus on catching misconduct. Academic consulting services (i.e., contract cheating companies) profit from what happens next, whether that means supplying unauthorized test answers before an assessment or, as we found in our research, or coaching students through misconduct hearings afterward.

So What’s Next?

The U of T injunction permanently restrains Easy EDU from making further use of the university’s course materials. The university has committed to directing settlement proceeds toward student academic supports. These are constructive outcomes, and also insufficient on their own.

In Academic Integrity in Canada: An Enduring and Essential Challenge, I, together with other contributors, called for legislation that would deter contract cheating firms from operating in Canada. That call has gone largely unanswered. The U of T case demonstrates that copyright enforcement can achieve results where academic integrity policy alone cannot, but copyright litigation is expensive, slow, and available only to institutions with the resources to pursue it. The case took four years to resolve, an in the financial climate we are in today, many institutions simply cannot absorb that kind of cost.

What the settlement does accomplish is normative because it establishes, through a federal court consent judgment, that reproducing course materials for commercial tutoring purposes constitutes copyright infringement. It names the professors whose intellectual property was taken and affirms, as U of T vice-provost Heather Boon stated, in Friesen’s article, that faculty own the copyright in their course materials and the university will support them in protecting it. That is a meaningful public statement. It signals that institutions are prepared to act, and that the legal tools to do so exist.

The Bigger Picture

Academic integrity is not simply a student conduct problem, but rather a structural problem shaped by institutional design, assessment practice, resource inequity, and the commercialization of educational support. The Easy EDU case sits at the intersection of all of these.

The students who attended those tutoring sessions needed academic support. Easy EDU positioned itself as that help, at a price, with materials it had no right to distribute. The university’s commitment to redirecting settlement funds to student supports is the right response. It will not be enough without sustained investment and clearer procedural guidance for students facing misconduct allegations. Institutions across our country happily received international student tuition fees, on the assumption that students are admitted have the academic skills and preparation they need to succeed. By and large, we still tend to blame the students if they lack academic skills or knowledge of how to navigate the higher education system. When the students turn to third parties whom they believe can help them fill their skills gap, historically, it is the students who are held responsible while companies operating in the background simply line their pockets with profits without any repercussions. This is the first time, to my knowledge, that a commercial supplier of academic services operating in Canada has faced a monetary penalty for facilitating academic misconduct.

Better institutional supports, clearer procedural guidance for students facing misconduct allegations, and platform-aware integrity education are not peripheral concerns. They are the conditions under which commercial exploitation becomes less attractive. In our study, Tang, Cai, and I call for a post-violation framework that attends to digital infrastructures and addresses students during crisis moments, not only before them. I continue to believe that work is overdue.

Kudos to the team at U of T for pursuing this case. You’ve now set a precedent that others can follow.

References

Eaton, S. E., & Christensen Hughes, J. (Eds.). (2022). Academic integrity in Canada: An enduring and essential challenge. Springer. https://doi.org/10.1007/978-3-030-83255-1

Friesen, J. (2026, May 22). University of Toronto reaches settlement for $1-million in damages from tutoring company. The Globe and Mail. https://www.theglobeandmail.com/canada/article-university-of-toronto-reaches-settlement-1-million-damages-tutoring  

Tang, G., Eaton, S. E., & Cai, W. (2026). Academic misconduct appeal services in China: Platform logics, self-platformization and implications for integrity education. British Educational Research Journal. https://doi.org/10.1002/berj.70130

______

Share this post: The University of Toronto Settlement Is a Turning Point for Academic Integrity in Canada – https://drsaraheaton.com/2026/05/22/the-university-of-toronto-settlement-is-a-turning-point-for-academic-integrity-in-canada/

Sarah Elaine Eaton, PhD, is a Professor and Research Chair in the Werklund School of Education at the University of Calgary, Canada. Opinions are my own and do not represent those of my employer.


AI, Postplagiarism and K-12 Education in New Brunswick, Canada

April 25, 2026

This week, I had the opportunity to take part in two leadership events led by the New Brunswick Department of Education and Early Childhood Development focused on artificial intelligence and education. 

On April 22 I gave a workshop on academic integrity and assessment with generative AI to educational leaders, academics, and professional staff at the AI Leadership Summit. The next day, I delivered a keynote address on postplagiarism, education and artificial intelligence at a province-wide summit on AI and education attended by almost 250 people from across the province.

I had an opportunity to meet and speak with the Hon. Claire Johnson, Minister of Education and Early Childhood Development, Deputy Minister Ryan Donaghy, and Assistant Deputy Minister Tiffany Bastin, all of whom commented on how postplagiarism aligns with their provincial strategy and policy vision. 

A group of people standing together.
(Left to right: Sarah Elaine Eaton, Sarah Rankin, Ryan Donaghy, Hon. Claire Johnson, Tiffany Bastin, Geoff Edwards, Robert Martellaci – April 2026, New Brunswick AI and Education Summit)

It was announced during the event that preparations are underway to integrate artificial intelligence into the provincial digital literacy strategy and educational curricula across all levels and subjects, with a plan to have AI fully integrated in time for the beginning of the next school year, starting in September, 2026. Staff at the Department of Education and Early Childhood Development are in the midst of updating curricula as we speak. 

To my knowledge, New Brunswick is the first province or territory in Canada to integrate AI across the K-12 curriculum. They are investing in professional learning for leaders, education specialists and developers, and educators, to improve and increase AI literacy levels throughout the education sector. Throughout the two days, I spoke with leaders and educators from across the province who repeated the same message to me, that postplagiarism was a refreshing and forward-thinking way to think about academic integrity, ethics, and student success in an AI-enabled world.

It was exciting and energizing to be brought into education conversations that connected policy, pedagogy, and postplagiarism. The real world applications of postplagiarism are taking shape and I am inspired to see how others are are findings ways to implement the framework as a future-focused roadmap for ethical learning and teaching with advanced technologies.

About the author: Sarah Elaine Eaton, PhD, is a Professor and the Director of the Postplagiarism Research Lab in the Werklund School of Education, University of Calgary.

______________

Reposted from original: AI, Postplagiarism and K-12 Education in New Brunswick, Canada – https://postplagiarism.com/2026/04/25/ai-postplagiarism-and-k-12-education-in-new-brunswick-canada/


Call for Proposals: Special issue on Postplagiarism and Generativism: Human-AI Hybrid Approaches to Ethical Teaching, Learning, and Assessment

March 17, 2026

Special Issue Call for Papers

Postplagiarism and Generativism: Human-AI Hybrid Approaches to Ethical Teaching, Learning, and Assessment

For publication in the Journal of University Teaching and Learning Practice

Guest editors

Background

Every new technology brings with it societal and moral panic (Orben, 2020). When the Internet first became popular, concerns about plagiarism increased. Even though there is scant empirical evidence that the Internet was actually responsible for increases in rates of plagiarism, the perception that new technology resulted in more academic cheating persisted (Panning Davies & Howard, 2016).

Some plagiarism scholars have been emphatic that the majority of student plagiarism cases are not an intent to deceive, but rather a lack of academic literacy and poor academic practice, and have even advocated for disposing of plagiarism in academic misconduct policies in favour of increased student support (Howard, 1992; Jamieson & Howard, 2021). The idea that plagiarism could be decoupled from academic misconduct seems somewhat unlikely, but by the 2020s it was obvious to some that generative artificial intelligence (GenAI) would have an impact on writing, and by extension, on plagiarism (Mindzak & Eaton, 2021).

In response to these technological shifts, various frameworks have emerged to conceptualize academic integrity in the GenAI era. The postplagiarism framework, first introduced by Eaton (2021, 2023) and since discussed by scholars worldwide (Bali, 2023; Bagenal, 2024; Kenny, 2024), offers one approach. Other perspectives, such as Generativism (Pratschke, 2023), AI Literacy frameworks (Ng et al., 2021; Pretorius & Cahusac de Caux, 2024), and UNESCO’s Guidance for Generative AI in Education (2023), provide complementary or alternative viewpoints on similar phenomena.

Postplagiarism is based on six tenets (Eaton, 2023): (1) human-AI hybrid writing will become the norm; (2) creativity can be enhanced by AI; (3) AI can help to overcome language barriers; (4) we can outsource control of our writing to AI, but we do not outsource responsibility for what is written; (5) attribution remains important; and (6) historical definitions of plagiarism may require rethinking.

Empirical testing of these and related frameworks has shown differing levels of acceptance and application across educational contexts (Kumar, 2025).

Equity, Diversity, Inclusion, and Accessibility in a Postplagiarism Age

As higher education institutions aim to promote social justice through equity, diversity, and inclusion (EDI), GenAI holds the potential to either break down or reinforce barriers related to linguistic, cultural, socioeconomic, and ability differences requires critical examination.

Assessment practices should be designed proactively to enable all students to demonstrate their learning without being unfairly disadvantaged by their personal characteristics or circumstances (Tai et al., 2022). Similarly, McDermott (2024) highlights the importance of considering accessibility, equity, and inclusion in assessment and academic integrity.

GenAI offers opportunities to enhance equity by providing personalized support, overcoming language barriers, and assisting learners with diverse needs. However, without careful implementation, it may exacerbate existing inequities through unequal access to technology, algorithmic biases, or assessment designs that privilege certain ways of knowing and communicating.

In this special edition, we propose to examine the broader question: “How are pedagogies, learning, and teaching approaches evolving in response to GenAI, and what frameworks best support ethical academic practice in a postplagiarism landscape?”

We invite researchers and practitioners to submit their original research papers exploring the transformation of teaching, learning, and assessment in a GenAI age. We welcome both theoretical and empirical contributions, including positions that may present contrasting viewpoints. Potential topics of interest include, but are not limited to:

  • New developments in postplagiarism, generativism, and other emerging frameworks for understanding academic integrity in the GenAI era
  • Empirical studies testing these frameworks in different contexts and disciplines
  • The use of these frameworks to design or reform academic misconduct policies and procedures
  • The relationship between GenAI, academic literacies, and related competencies (e.g., digital literacy, information literacy)
  • Pedagogical approaches that embrace GenAI while maintaining academic integrity
  • Case studies of successful integration of GenAI into teaching, learning, and assessment
  • Critical perspectives on the limitations or challenges of current approaches to GenAI in education
  • Position papers presenting new or alternative frameworks for understanding GenAI in teaching and learning

We particularly encourage submissions that engage in dialogue with existing frameworks, offering either supportive evidence or critical alternatives. Our goal is to foster a robust debate about the future of teaching and learning in a GenAI (and even a post-GenAI) world.

We welcome submissions from both established researchers and early-career scholars from diverse academic and cultural backgrounds. All submissions will be peer-reviewed by an international panel of experts. Accepted papers will be published in a special issue of the Journal of University Teaching and Learning Practice.

Types of publications accepted into this Special Issue

The types of publications that are eligible for acceptance into this Special Issue include:

  • Research papers
  • Review articles (e.g., systematic review or meta-analysis)
  • Case studies and evidence-based good practice examples

Developing a high-quality proposal

We recommend the creation of a single document in Word (.doc or .docx) format that contains the following:

  • Proposed article title
  • Proposed authors names, affiliations, and ORCid
  • A clear evidence-based rationale for the line of inquiry proposed
  • Research question(s)
  • Proposed method (for both theoretical and empirical manuscripts)
  • Practice-based implications of the proposed research

The word limit for the proposal is 250 words (not including references) and is designed to give the Editorial Team a sense of the rigour of the manuscript proposed and the possible implications of such research. The Editorial Team may return with an invitation to combine similar manuscripts. Acceptance of proposals does not guarantee acceptance of final manuscripts.

Timeline

  • Proposals due – April 30, 2026
  • Proposal acceptance notifications: May 14, 2026
  • Full articles due: August 31, 2026

Submit your abstract via this online form: https://forms.gle/6sKjc2jkKGWCtGgw7

For further information contact Professor Sarah Elaine Eaton, University of Calgary.

References

Bali, M. (2023, March 3). Are We Approaching a Postplagiarism Era? https://blog.mahabali.me/educational-technology-2/are-we-approaching-a-postplagiarism-era/

Bagenal, J. (2024). Generative artificial intelligence and scientific publishing: Urgent questions, difficult answers. The Lancet, 403(10432), 1118–1120. https://doi.org/10.1016/S0140-6736(24)00416-1

Eaton, S. E. (2021). Plagiarism in Higher Education: Tackling Tough Topics in Academic Integrity. Bloomsbury.

Eaton, S. E. (2023). Postplagiarism: Transdisciplinary ethics and integrity in the age of artificial intelligence and neurotechnology. International Journal for Educational Integrity, 19(1), 1–10. https://doi.org/10.1007/s40979-023-00144-1

Orben, A. (2020). The Sisyphean cycle of technology panics. Perspectives on Psychological Science, 15(5), 1143–1157. https://doi.org/10.1177/1745691620919372

Howard, R. M. (1992). A plagiarism pentimento. Journal of Teaching Writing, 11(2), 233–245.


ChatGPT is in classrooms. What now?

February 2, 2026

“What should we be assessing exactly?” This was a question one of our research participants asked when we interviewed them as part of our project on artificial intelligence and academic integrity, sponsored by a University of Calgary Teaching Grant.

In an article published in The Conversation, we provide highlights of the results from our interviews with 28 educators across Canada, as well as our analysis of 15 years of research that looked at how AI affects education. (Spoiler alert: AI is a double-edged sword for educators and there are no easy answers.)

Alt text: Screenshot of The Conversation website showing a blurred smartphone screen with the ChatGPT app icon. Overlaid headline reads, “ChatGPT is in classrooms. How should educators now assess student learning?”
Screenshot from The Conversation.

We emphasize that, “in a post-plagiarism context, we consider that humans and AI co-writing and co-creating does not automatically equate to plagiarism.” Check out the full article in The Conversation.

You can check out the scholarly paper that we published in Assessment and Evaluation in Higher Education that goes into more detail about the methods and findings of our interviews.

I’d like to give a shoutout to all the project team members who worked with us on various aspects of this research: Robert (Bob) Brennan (Schulich School of Engineering, University of Calgary), Jason Weins (Faculty of Arts, University of Calgary), Brenda McDermott (Student Accessibility Services, University of Calgary), Rahul Kumar (Faculty of Education, Brock University), Beatriz Moya (Instituto de Éticas Aplicadas, Pontificia Universidad Católica de Chile) and the student research assistants who helped along the way (who have now all successfully graduated and moved on to the next phase of their careers): Jonathan Lesage, Helen Pethrick, and Mawuli Tay.

Related posts:

What Should We Be Assessing in a World with AI? Insights from Higher Education Educators – https://drsaraheaton.com/2025/11/25/what-should-we-be-assessing-in-a-world-with-ai-insights-from-higher-education-educators/

______________

Share this post: ChatGPT is in classrooms. What now? https://drsaraheaton.com/2026/02/02/chatgpt-is-in-classrooms-what-now/

Sarah Elaine Eaton, PhD, is a Professor and Research Chair in the Werklund School of Education at the University of Calgary, Canada. Opinions are my own and do not represent those of my employer.


What Should We Be Assessing in a World with AI? Insights from Higher Education Educators

November 25, 2025

The arrival of generative AI tools such as ChatGPT has disrupted how we think about assessment in higher education. As educators, we’re facing a critical question: What should we actually be assessing when students have access to these powerful tools?

Our recent study explored how 28 Canadian higher education educators are navigating this challenge. Through in-depth interviews, we discovered that educators are positioning themselves as “stewards of learning with integrity” – carefully drawing boundaries between acceptable and unacceptable uses of chatbots in student assessments.

Screenshot of an academic journal article header from Assessment & Evaluation in Higher Education, published by Routledge. The article title reads: “What should we be assessing exactly? Higher education staff narratives on gen AI integration of assessment in a postplagiarism era.” Authors listed are Sarah Elaine Eaton, Beatriz Antonieta Moya Figueroa, Brenda McDermott, Rahul Kumar, Robert Brennan, and Jason Wiens, with institutional affiliations including University of Calgary, Pontificia Universidad Católica de Chile, Brock University, and others. The DOI link is visible at the top: https://doi.org/10.1080/02602938.2025.2587246.

Where Educators Found Common Ground

Across disciplines, participants agreed that prompting skills and critical thinking are appropriate to assess with chatbot integration. Prompting requires students to demonstrate foundational knowledge, clear communication skills, and ethical principles like transparency and respect. Critical thinking assessments can leverage chatbots’ current limitations – their unreliable arguments, weak fact-checking, and inability to explain reasoning – positioning students as evaluators of AI-generated content.

The Nuanced Territory of Writing Assessment

Writing skills proved far more controversial. Educators accepted chatbot use for brainstorming (generating initial ideas) and editing (grammar checking after independent writing), but only under specific conditions: students must voice their own ideas, complete the core writing independently, and critically evaluate any AI suggestions.

Notably absent from discussions was the composition phase – the actual process of developing and organizing original arguments. This silence suggests educators view composition as distinctly human cognitive work that should remain student-generated, even as peripheral tasks might accommodate technological assistance.

Broader Concerns

Participants raised important challenges beyond specific skill assessments: language standardization that erases student voice, potential for overreliance on AI, blurred authorship boundaries, and untraceable forms of academic misconduct. Many emphasized that students training to become professional communicators shouldn’t rely on AI for core writing tasks.

Moving Forward

Our findings suggest that ethical AI integration in assessment requires more than policies, it demands ongoing conversations about what makes learning authentic in technology-mediated environments. Educators need support in identifying which ‘cognitive offloads’ are appropriate, understanding how AI works, and building students’ evaluative judgment skills.

The key insight? Assessment in the AI era isn’t about banning technology, but about distinguishing between tasks where AI can enhance learning and those where independent human cognition remains essential. As one participant reflected: we must continue asking ourselves, “What should we be assessing exactly?”

The postplagiarism era requires us to protect academic standards while preparing students for technology-rich professional environments – a delicate balance that demands ongoing dialogue, flexibility, and our commitment to learning and student success.

Read the full article: https://doi.org/10.1080/02602938.2025.2587246

______________

Share this post: What Should We Be Assessing in a World with AI? Insights from Higher Education Educators – https://drsaraheaton.com/2025/11/25/what-should-we-be-assessing-in-a-world-with-ai-insights-from-higher-education-educators/

Sarah Elaine Eaton, PhD, is a Professor and Research Chair in the Werklund School of Education at the University of Calgary, Canada. Opinions are my own and do not represent those of my employer.