Discussion of TOEFL 2000 in the TOEFL Committee of Examiners' (COE) meetings resulted in a framework representing components believed to be relevant to defining language use in an academic context. The framework, called the COE Model, is comprised of aspects of the context of language use as well as hypothesized capacities of the language user. The COE Model suggests that test development should begin by examining the types of academic contexts in which language is used in order to hypothesize what those abilities may be for any specific context of interest. COE discussions of TOEFL 2000 were motivated by a broad range of validity concerns (e.g., content validity, construct validity, and the social consequences of test use), and the Model may have implications for how validation of TOEFL 2000 is conceived. The COE Model is described to serve as a record of past discussion which can inform future work.