Drawing on experience between 2000 and 2007 in developing a validity argument for the high-stakes Test of English as a "Foreign Language[TM]" (TOEFL[R]), this paper evaluates the differences between the argument-based approach to validity as presented by "Kane (2006)" and that described in the 1999 "AERA/APA/NCME Standards for Educational and Psychological Testing." Based on an analysis of four points of comparison--framing the intended score interpretation, outlining the essential research, structuring research results into a validity argument, and challenging the validity argument--we conclude that an argument-based approach to validity introduces some new and useful concepts and practices. (Contains 2 tables and 4 figures.)