27 September 2021
Mr Steven Lee & Mr Sidd Sharma
Australian Competition and Consumer Commission
The Group of Eight (Go8) is pleased to make this submission responding to the Australian Competition and Consumer Commission’s Statement of Issues entitled Turnitin, LLC – proposed acquisition of Ouriginal Group AB.
The Go8 represents Australia’s eight leading research-intensive universities. The Go8 carries out 70 per cent of Australia’s university research and spends some $6.5 billion on research each year.
As a collective we:
- are consistently the highest ranked Australian universities across the major international ranking systems (Academic Ranking of World Universities; the Times Higher Education World University Rankings; and the QS World University Rankings);
- currently educate over 420,000 enrolled students; and
- educate around one in three international students who choose to study onshore in Australia.
All Go8 universities currently utilise Turnitin products as a dominant anti-plagiarism software (APS) provider.
The Go8’s predominant concerns with the proposed acquisition of Ouriginal by Turnitin relate to the potential for higher prices and lower service quality, although there are some concerns about reduced product innovation, especially in the context of concerns about existing stagnation in innovation at Turnitin. Across the Go8, only Turnitin and Ouriginal are considered providers with products that possess the functionality required by our universities, especially in terms of the depth of their assignment/assessment databases and investigative capacity, although other services – including Cadmus and iThenticate – are used to supplement this functionality.
- The Go8 recommends that the ACCC does not approve the proposed acquisition of Ouriginal Group AB by Turnitin, LLC predominantly based upon on the concern for the resulting market concentration in higher education anti-plagiarism software providers, and the likelihood that this will result in higher prices and lower service quality for Go8 and other Australian universities.
Responses to ACCC questions
How easy or difficult would it be for providers of LMS (or other educational software such as grading or feedback tools) to begin supplying APS?
It is a significant challenge for other providers of LMS to be competitive in the supply of anti-plagiarism software (APS) as creating an assignment/assessment database with the necessary depth takes many years to develop. For example, one Go8 university has reported that “It would be difficult and would set back our investigative capacity by several years. The depth of the assignment database is very important so that we can detect if a student has copied an assignment from another institution or from a previous student at [our university].”
Would it be viable for educational institutions to use a student-facing APS, such as Grammarly, for academic integrity purposes? Why or why not?
The key advantage is that it would allow students to correct plagiarism issues prior to the submission of assignments/assessments; however, as above, the lack of depth of the database would be a key disadvantage.
Generally speaking, Turnitin is considered to outperform Grammarly in being able to detect plagiarism. As reported by one Go8 university: “…student-facing APS serves an educational purpose which complements rather than replaces detection and investigation tools such as Turnitin.”
What changes would a provider such as Grammarly need to make to their software for it to be a viable alternative to Turnitin or Ouriginal?
Other providers would need to significantly improve the accuracy of their APS and be competitive on price. Universities also require that the provider offers investigative capacity beyond the student-facing APS.
Do higher education customers and K-12 customers have different requirements for APS? Please explain why and outline the key differences in APS functionality and capability needed to serve each group of customers.
Go8 universities require APS that can service large student cohorts, access academic journal databases, and be able to perform writing style comparisons that detect contract cheating; these are likely requirements that are not as necessary for K-12 customers.
How important are each of the following features of APS to higher education and secondary education customers, respectively:
- the ability to search against a cross-institution database of previously submitted student works
- the ability to search against an extensive range of academic journal articles
- local customer support based in Australia
- storage of any databases in Australia as opposed to overseas
- the reputation of the APS provider, including the extent to which it is already being used by other educational institutions.
How easy or difficult would it be for APS suppliers to expand from supplying the K-12 sector (for example, secondary schools) to supplying higher education customers in Australia?
The Go8 does not have a clear view of exactly how difficult this may be for K-12 APS suppliers, however key challenges include being able to access databases of academic journals, as well as sufficiently large databases of university assignments/assessments.
Increased prices/decreased service levels for Australian higher education customers
Please list the APS providers you consider are suitable options for Australian higher education institutions and explain why.
Turnitin and Ouriginal are the only two providers that Go8 universities would consider suitably able to provide the functionality required, especially because of the depth of their assignment/assessment databases, journal databases, and investigative capacity.Other suppliers in the market include Blackboard, Copyleaks, Drillbit, Grammarly, PlagiarismCheck, and UniCheck.
Which companies not currently supplying APS to Australian higher education institutions are best placed to begin doing so and why? What steps would they need to take to be successful?
The Go8 does not hold a clear view on which companies would be best placed to begin competing in the Australian higher education APS market, although one Go8 university indicated the company Canvas “as they are a large company that already has good market share in the LMS space.”
Please provide your views on the significance of, and the difficulty of overcoming, the following barriers to entry and expansion in the relevant market:
- the need to build cross-institutional databases and the number of institutions’ materials that needs to be included
This is the main barrier to entry: building new databases is a serious endeavour that would require at least several years of sustained and successful business effort. However, universities being able to migrate their content from a current APS provider to a new provider would partially overcome this barrier.
- the importance of product reputation and the transferability of reputation earned in overseas jurisdictions to the Australian market
As noted by one Go8 university: “Reputation is important but not insurmountable, as a good product with good overseas reference customers would be competitive in a formal tender process for APS.”
- access to a comprehensive subscription-based academic journal database and the annual cost of inaugurating and maintaining such a database
This is considered another major and expensive barrier.
- customer switching costs and difficulties
Not insurmountable if it integrates easily with university LMS (e.g. Canvas) but would need careful planning over 12 – 24 months. Main cost would be user training and testing. If migration of database from incumbent is possible this would add cost and complexity.
- any other potential barriers not listed above (please describe them).
Whether their technical support team and accounts team is located in Australia and thus able to provide timely and contextual support.
Turnitin’s reduced incentive to innovate
The ACCC invites comments from market participants on its preliminary concern that the proposed acquisition may reduce Turnitin’s incentive to innovate. In particular, market participants may wish to comment on the following:
- The extent to which Ouriginal is a particularly innovative APS provider.
Ouriginal is the only other vendor that is largely considered as competitive with Turnitin in terms of functionality. As reported by one Go8 university: “Examples of innovation include the use of optical character recognition (OCR) including ability to recognise handwritten work, and “stylometry” to check consistency in student writing style (to combat contract cheating).”
- Whether there are other actual or potential competitors who are likely to drive innovation in APS.
Blackboard, Go Assignment, Grammarly, and UniCheck can be considered as the salient actual and potential competitors likely to drive innovation in APS.
The Go8 wishes to thank the Commission for the opportunity to submit a response to its Statement of Issues on Turnitin, LLC – proposed acquisition of Ouriginal Group AB.
If you have questions regarding the submission, please do not hesitate to contact me directly at firstname.lastname@example.org or 0417 808 472.
 Latest figures (2019 enrolments); Higher Education uCube, Department of Education, Skills and Employment; http://highereducationstatistics.education.gov.au/