This paper illustrates a method of item analysis used to identify discriminating multiple-choice items in placement data. The data come from two rounds of pilots given to both SHL students and Spanish as a Second Language (SSL) students. In the first round, 104 items were administered to 507 students. After discarding poor items, the second round presented 64 items to 330 students. Both graphical and statistical item analyses were employed. Graphical analysis involved an examination of trace-line graphs of each item. A fine-grained statistical analysis was conducted using point-biserial correlation coefficients. Both of these methods were useful and contributed to measure reliability. Different sets of items were selected for each learner group: 31 items for SHL participants and 21 for SSL participants. These items are currently being used in a preliminary online placement exam; after taking a biographical questionnaire, students are piped to either the SHL exam or the SSL exam. Finally, this paper examines characteristics of SHL students found in these data and finds that regional characteristics should be considered in item creation in terms of answer variability and possible distinction between SHL and SSL students. (Contains 13 tables, 2 figures, and 3 notes.)