In the paper, different approaches of process modelling in e-learning system development are investigated. We provide a look at the DIN PAS 1032-1 and in the process model ROME, which is a derivation of the DIN PAS 1032-1. ROME has been extended by several pattern approaches. However, after several years of using ROME, we found out that ROME has some major flaws, which can be traced back to the so-called top-down approach. In ROME, the decision for a certain type of e-learning system is the first step. After this, the process model is used to structure the development process. In reality, in most cases a bottom-up approach would be better suited: centred around the learner and focused on the learner's needs, a content reduction and development should take place, and later, as second level step in the process, a decision for a certain e-learning type can take place. [For the full proceedings, see ED562093.]