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The proliferation of Web-based learning objects makes finding and evaluating online resources problematic. While established Learning Analytics methods use Web interaction to evaluate learner engagement, there is uncertainty regarding the appropriateness of these measures. In this paper we propose a method for evaluating pedagogical activity in Web-based comments using a pedagogical framework, and present a preliminary study that assigns a Pedagogical Value (PV) to comments. This has value asdoi:10.1109/icalt.2015.62 dblp:conf/icalt/ORiordanMS15 fatcat:vgooxjvcwrhnhntw4dulxplyxm