Evaluate overall
SEO, both on-page and off-page - especially the number of back links.
Also do a Google search like this:
allintitle: "key phrase in quotes"
A raw search may bring up 11 million competing but most of those may not even be strong competition at all, just happen to have the keywords somewhere on the page. Using allintitle, as above, only shows the pages that are serious competition and have the exact keywords in the title tag. If that number is reasonable, then evaluate what the top 10 are doing and how many back links they have and then try to outdo them.