E-learning is a new strategic arena for higher education, and higher education institutions (HEIs) need to acquire the necessary competencies and capabilities to participate. These may be developed in-house or acquired externally. E-learning involves acquisition and management of new information systems, and deployment of new capabilities. A resource-based view (RBV) suggests a rational stepwise model of how organisations approach entry to a new strategic area. This research uses case analysis in five universities to test this view and identifies two models for implementing e-learning, one confirming the rational model, and one that is emergent. These outcomes permit a richer RBV of strategy, and suggest a diverse range of strategic options for HEIs as they engage in e-learning.