The IMS Learning Design (LD) specification was introduced as an answer to the shortcomings of existing learning technology specifications. The main difference with existing specifications is that LD is an abstract, conceptual model that is able to express various pedagogical approaches whereby content can be adapted to personal needs and test objects can be integrated. In this article we evaluate the pedagogical expressiveness of LD by taking a set of 12 lesson plans and expressing them in LD. We use three different methods to identify difficulties in expressing the lesson plans in LD. Difficulties found included circulating a document in a group, a message-giving prior to the start of an activity, random assignment of a group member to a role, group formation at runtime, creation of an inventory to map pre-knowledge, learning objectives and learning achievements, and a way to communicate information on how to deliver a lesson to a teacher. We did not find situations that were impossible to express with LD. The found difficulties are elaborated and suggestions to handle them are given. The methods used are compared and suggestions are given for further research.