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I think it is wrong to inject an accusation of cheating in this manner. As far as a copy from scenario, that would involve two "cheaters."
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That's why I would lean towards my second hypothetical scenario where a student steals the multiple choice answer sheet to the Week 12 exam, passes it around the class for the Week 11 test, and 15 people get a 12/50, with the exact same 38 wrong answers. With that many people involved, you really have no idea who started the chain. If there were only a couple people involved, you would know that one or both of them cheated, and you'd address the issue with them, not the entire class.