Although digital equity is a recognized challenge in our K-12 school system, there is little research in using a holistic framework to investigate pre-conditions necessary for K-12 students to participate in digital learning and online processes. A conceptual framework of students' digital opportunity (SDO) is developed to represent the essential components of digital connectivity. The four key components are broadband internet availability, broadband usage, digital device ownership, and speed quality. A composite measure of SDO was created to quantitatively represent and measure the differences across 3,138 counties in the United States. Furthermore, spatial autocorrelation was applied to evaluate if the distribution of the SDO score is associated with geographical characteristics at the county level. The result showed the presence of significant county-level clusters with concentrations of high or low SDO scores. While the spatial analysis provided evidence of where the gaps in digital opportunities are located, there are underlying factors at the micro level that would need further investigation. This study suggests a collective approach between private and public entities to address the K-12 digital equity issue. The necessary conditions presented in the SDO model must be addressed first in order to bring change to K-12 students and schools in terms of obtaining high quality and reliable broadband internet and digital devices for learning with technology. Two research outputs are available from this research to allow others to further evaluate digital equity among K-12 schools and students.