This research study looks at how organizations in developing countries perceive the challenge of building capacity in e-learning expertise. Data was collected on six such organizations, and a range of perceived rationales and constraints were identified. The paper hypothesizes a four-part framework to define the e-learning capacity gaps that these circumstances appear to represent: the "instructional design capacity gap", the "production capacity gap", the "tutorial capacity gap" and the "community building gap". The framework is used to re-examine the data to explore the ways in which the organizations' e-learning activities might constitute strategic responses to the hypothesized capacity gaps.