By Steven Yaccino, U.S. News & World Report, October 3, 2008

In addition to repurposing the labels on soda bottles, students continue to explore other new avenues in cheating.

Customization. While some students busy themselves plotting ways to manipulate documents and trick antiplagiarism software like Turnitin.com, the Internet is inundated with places where lazier students can order custom "plagiarism-free" essays on any subject. These papers could be a major problem in classrooms because there is no way to identify them. One site touts a staff of hundred of writers who will even attempt to duplicate students' writing style. But professors say they can generally tell that students are plagiarizing when they use concepts and style too sophisticated for their education level.

http://www.usnews.com/articles/education/2008/10/03/cheating-students-use-technology-too.html