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One challenge facing some item writers arises when there is a need to distinguish between the academic language and the academic content of a test (Anstrom et al, 2010), particularly on mandated language proficiency tests for English language learners. The purpose of this study was to engage experienced item writers in an investigation to understand how they operationalize linguistic complexity in order to collect specific examples of academic language and describe their linguistic features at different proficiency levels, grade clusters and content areas in order to inform training of junior item writers and scholarly inquiry in this field. Participants identified six features which contributed to linguistic complexity: vocabulary; sentence/grammatical structures; task/cognitive complexity; visual support/text features; item presentation; and test-taking strategies.