This presentation identifies emerging themes in a study combining documentation analysis (Atkinson & Coffey, 2004) and interviews that examine policy statements, promotional materials and various institutional documents from selected English as a Second Language (ESL) programs at one Canadian University. It looks at how and why ESL programs are perceived to be tools for revenue generation and some of the implications this has, both at the program and institutional levels. The philosophical, ethical and practical challenges of international marketing of educational programs that generate revenue are explored.