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Despite strong interest in learning analytics (LA) adoption at large-scale organizational levels continues to be problematic. This may in part be due to the lack of acknowledgement of existing conceptual LA models to operationalize how key dimensions of adoption interact to better inform the realities of the implementation process. This paper proposes the framing of LA adoptionin complexity leadership theory (CLT) to study the overarching system dynamics. The framing is empirically validated in a study analysing interviews with senior managers of Australian universities (n=32). The results were coded for several adoption dimensions (e.g., leadership, governance, staff development, and culture). The coded data were then analysed with latent class analysis. The results identified two classes of universities that either i) followed an instrumental approach to adoption - typically top-down leadership, large scale project with high technology focus yet demonstrating limited staff uptake; or ii)were characterized as emergent innovators –bottom up, strong consultation process, but with subsequent challenges in communicating and scaling up innovations. The results suggest there is a need to broaden the focus of research in LA adoption models to move on from small-scale course/program levels to a more holistic and complex organizational level
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