This article explores the role of state education agencies in three states that have embarked on ambitious kindergarten through Grade 12 (K-12) virtual learning initiatives: Alabama, Florida, and Idaho. Subject to a rapidly changing environment influenced by factors beyond the jurisdiction of many state departments of education, the world of virtual K-12 education is relatively unregulated and fluid. Case studies describing the virtual learning initiatives of several states suggest that few, if any, state education agencies are currently equipped to regulate the rapidly growing number of independent for-profit and nonprofit organizations delivering online learning options. (Contains 1 figure and 24 footnotes.)