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

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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.


Interfacing with the Future: Reflections on the National Day of Learning 2026

April 1, 2026

On March 28, 2026, I had the pleasure of joining educators from across Canada for the National Day of Learning, hosted by Let’s Talk Science. This one-day, nation-wide professional learning event brought together K–12 teachers, post-secondary educators, and policy leaders to explore some of the most pressing issues shaping education today, with artificial intelligence high on the agenda.

I was invited to deliver a session titled “Interfacing with the Future: Wearable AI and Academic Integrity for K–12 and Higher Ed.” What follows are a few reflections and key ideas from that conversation, hosted by Dr. Alec Couros.

Moving into the Postplagiarism Era

One of the central ideas framing my talk is postplagiarism. In this reality, artificial intelligence is no longer an external tool that students occasionally use, but rather, it is embedded into everyday life and learning.

Students are already engaging with AI in ways that challenge traditional notions of authorship, originality, and academic work. The question is no longer if students will use AI, but how.

This shift requires a corresponding change in how we think about academic integrity. Detection and surveillance, long relied upon as primary strategies, are no longer sufficient. Instead, we must rethink how we design learning environments that foster integrity from the ground up.

From Tools to Wearables: How AI is Advancing

A key focus of my presentation was the rapid evolution from AI tools to AI wearables — particularly smart glasses and other forms of cosmetically invisible interfaces. The talk was based, in part, on our recent article in Canadian Perspectives on Academic Integrity

Wearable technologies integrate AI directly into our physical experience of the world. Rather than pulling out a device, users can access real-time information, transcription, and prompts seamlessly through their field of vision.

This shift introduces both opportunities and tensions:

  • Cognitive offloading: Learners can reduce mental load by accessing information instantly. (Phill Dawson has done some great work on cognitive offloading that I recommend reading.)
  • Enhanced presence: Wearables allow users to maintain eye contact and engagement without device distraction.
  • Efficiency gains: Tasks such as note-taking or translation can be automated in real time.

At the same time, these benefits come with real challenges including information overload, privacy concerns, and technical limitations. More importantly for educators, they fundamentally disrupt assumptions about what it means to “know” something independently.

New Technology ≠ Cheating

One of the most important messages I emphasized is this: new technology does not automatically equal academic misconduct.

If a tool is permitted, then its use is not cheating. The real issue lies in unauthorized use or misuse in ways that create unfair advantage. 

We must also remain attentive to equity and accessibility. Some wearable technologies may be used as accommodations, making it essential that our integrity policies are inclusive and nuanced rather than rigid and punitive.

Designing for Integrity (Not Surveillance)

Rather than doubling down on detection, I encourage educators to shift their focus toward designing for integrity.

This means:

  • Prioritizing assessment validity: If an AI system can complete a task without genuine understanding, then the task itself needs to be rethought.
  • Moving beyond “gotcha” approaches: Surveillance-based strategies erode trust and are increasingly ineffective.
  • Supporting diverse learners: Students bring different technological access, needs, and experiences. Our designs must reflect that.
  • Building a culture of integrity: Integrity is not enforced; it is cultivated through meaningful learning experiences.

Bridging K–12 and Post-Secondary Education

Another key theme was the gap between K–12 and post-secondary expectations.

In K–12 environments, students are often encouraged to explore technology as part of their learning. In contrast, post-secondary institutions frequently operate under the assumption that students already understand complex academic integrity rules.

As AI continues to evolve, this gap becomes more pronounced. We need stronger alignment across educational sectors to ensure that students are supported, rather than being set up for failure, as they transition between systems. (Myke Healy has a great paper on the topic of GenAI in the K-12 context that is worth reading.) 

Looking Ahead

If there is one takeaway from this experience, it is this: wearable AI is not a future scenario. It is already here.

As educators, we are being called to respond not with fear, but with thoughtful, research-informed approaches. The challenge is not simply to manage technology, but to reimagine teaching, learning, and assessment in ways that remain meaningful in an AI-integrated world.

Events like the National Day of Learning remind me of the power of community. Bringing educators together to share ideas, ask difficult questions, and explore new possibilities is essential as we navigate this rapidly changing landscape.

Thank you to Let’s Talk Science and to Dr. Alec Couros for the opportunity to be part of this important conversation, and to all the educators who continue to lead with curiosity, courage, and care.

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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.


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/

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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.


Decriminalizing the Language of Academic Integrity

October 2, 2025

The first time I heard about decriminalizing the language and processes we use to address cases of plagiarism and other forms of academic misconduct; I was riveted. It was at an academic integrity conference in Richmond, Virginia and the lead presenter was Dr. James Earl Orr, who presented together with students on how a developmental and supportive approach to academic misconduct case management can help lead students towards academic success while still holding them responsible for their behaviour.  James Earl Orr, writing together with Karita Orr, published an excellent article on using restorative practices to resolve academic integrity violations.

When I was writing the University of Calgary’s academic integrity Handbook for Academic Staff and Teaching Assistants, I took the opportunity to apply what I had learned from listening to Dr. Orr at conferences and reading his work by including a section on how to decriminalize the language we use to talk about academic misconduct.

Academic integrity violations are rarely criminal in nature and yet, much of the language we use when addressing plagiarism and academic cheating is legalistic, setting the stage for criminalizing student behaviour. One step towards taking a more learner-centred approach to misconduct is to decriminalize the language we use to talk about breaches of academic integrity.

Front cover: Student Academic Integrity Faculty Handbook
Front cover of the Student Academic Integrity Faculty Handbook, published by the Taylor Institute for Teaching and Learning at the University of Calgary

The following is an excerpt from the University of Calgary’s academic integrity Handbook for Academic Staff and Teaching Assistants that provides practical guidance on how to do this:

“We know that words matter and the language we use is important. A full list of terms related to academic misconduct is available in our policy. It should be noted that the terms “academic integrity” and “academic misconduct” are not interchangeable.

Academic integrity is about acting ethically in teaching, learning and research contexts. We do not report, investigate or manage cases of academic integrity. We report, investigate and manage cases of academic misconduct.

Academic misconduct is what happens when individuals do not act with integrity. This is currently the language used in our policy and procedures. When speaking and writing about academic misconduct, we can use the terms “breaches of integrity or “violations of integrity” as synonyms for academic misconduct.

At the University of Calgary we take a proactive approach to academic integrity, including in the language we use and in keeping the focus on teaching, learning and fairness to students. In our conversations with students and others, it can be helpful to use the language of integrity that focuses on education and support” (Eaton, 2022, p. 13).

See the table below, which is also an expert from our handbook (with a few minor updates):

The language of academic integrity

Preferred
language
Language
to avoid 
Explanation
Hold responsible Guilt
Guilty

The words “guilt” and “guilty” do not appear anywhere in our
polices or procedures. We do not find students guilty of academic misconduct, but instead we hold them responsible for their
behaviours.
Sanctions
Consequence
Outcome
Punish
Punishment

When disciplinary actions are taken in response to academic
misconduct, we do not use the terms “punish” or “punishment”
in our institutional documents. We opt instead for “sanctions”,
“discipline,” “consequences” or “outcome” which can include educational responses depending on the misconduct.
Hearing Trial 
The University of Calgary does not conduct trials related to
academic misconduct.
In other countries, various forms of academic misconduct can be
considered an offense under the criminal code and students may
be required to attend a criminal trial. That is not the case at the
University of Calgary or anywhere in Canada.
In the case of an appeal, a hearing might occur. In rare cases, an appeal case might escalate to an externally reviewed case in court, but these proceedings are not administered by the university itself.

When I talk about taking a postplagiarism approach to academic integrity I am talking about disrupting historically adversarial and antagonistic approaches to misconduct that pit students against their teachers. It is time to move past crime-and-punishment approaches to student misconduct where students are the villains and teachers are the heroes. When we talk about postplagiarism we talk about social justice and student success as being intertwined, and we focus on students as stewards of the future, who will be best equipped for an increasingly complex world when they understand the importance of ethical decision-making, both in theory and in practice.

Postplagiarism does not mean anything goes, and nor does it mean that we turn a blind eye to misconduct. Postplagiarism is about finding socially just ways to address misconduct include relationally, restoration, and the preservation of dignity and human rights. When we decriminalize language related to student misconduct, we are taking a step towards dignity and   student success.

Our University of Calgary’s academic integrity Handbook for Academic Staff and Teaching Assistants is an open access handbook with a Creative Commons license. This means you can share and adapt the material, providing the original work is properly attributed.

If this is helpful to you, please share this with others.

References and Further Reading

Eaton, S. E. (2022). Student Academic Integrity: A Handbook for Academic Staff and Teaching Assistants. University of Calgary, Taylor Institute for Teaching and Learning Guide Series. https://taylorinstitute.ucalgary.ca/resources/student-academic-integrity-handbook

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

Eaton, S. E. (2025). Global Trends in Education: Artificial Intelligence, Postplagiarism, and Future-focused Learning for 2025 and Beyond – 2024–2025 Werklund Distinguished Research Lecture. International Journal for Educational Integrity, 21(1), 12. https://doi.org/10.1007/s40979-025-00187-6

Orr, J. E., & Hall, J. (2018). Student-led case adjudication: Promoting student learning through peer-to-peer engagement. 25th Annual International Center for Academic Integrity (ICAI) Conference, Richmond, VA.

Orr, J. E., & Orr, K. (2023). Restoring honor and integrity through integrating restorative practices in academic integrity with student leaders. Journal of Academic Ethics, 21, 55–70. https://doi.org/10.1007/s10805-021-09437-x

Orr, J. E., & Orren, S. (2018, March 4). The Development & Implementation of a Campus Academic Integrity Education Program. 25th Annual International Center for Academic Integrity (ICAI) Conference, Richmond, VA.

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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.


Bibliography of Equity, Diversity, Inclusion, and Accessibility Resources for Academic Integrity

September 12, 2025

This week I did an invited presentation for the European Network for Academic Integrity (ENAI) Integrity for All Working Group.

As part of my presentation, I shared this bibliography of resources that I’ve worked on over the past several years on academic integrity as it relates to equity, diversity, inclusion, accessibility, and decolonization. These topics have become increasingly important to me over the past half decade and it is more important now than it ever has been to elevate the importance of these topics, along with human rights and social justice, when addressing matters of student conduct.

This bibliography contains a list of academic integrity articles, presentations, and resources that focus on these topics. 

I’ve done my best to prepare this list according to APA 7 conventions, but please forgive any errors.

I aim to make as much of my content open access. If there is anything on this list that you cannot access, please contact me directly and I’ll see what I can do.

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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.