Thesis advisor: Hans de Wit / Thesis advisor: Rebecca C. Schendel / CUValles has no intentional, integrated institutional pathway to comprehensive internationalization. Consequently, the primary purpose of this transformative inquiry is to analyze how comprehensive internationalization might be achieved at CUValles: a constituent of a decentralized, multi-campus University Network. Interviews with 12 key informants and official document analysis were the means of data collection. Findings indicate the disarticulated presence of all comprehensive internationalization as characterized by ACE, (2017). Comprehensive internationalization might be achieved at CUValles through a context savvy application of de Wit’s Internationalization Cycle (2002), integrated from an “Inter-Campus Research Institute for International Higher Education”. / Thesis (MA) — Boston College, 2020. / Submitted to: Boston College. Lynch School of Education. / Discipline: Educational Leadership and Higher Education.