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 as

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... categorises discussion in terms of pedagogical activity rather than Web interaction. Results show that PV is distinct from typical interactional measures; there are negative or insignificant correlations with established Learning Analytics methods, but strong correlations with relevant linguistic indicators of learning, suggesting that the use of pedagogical frameworks may produce more accurate indicators than interaction analysis, and that linguistic rather than interaction analysis has the potential to automatically identify learning behaviour.