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P.O. Box 2600
Valley Forge, PA 19482-2600
610-669-2689
nathan_m_will@vanguard.com
May 31, 2011
Brion Thompson, Esq.
U.S. Securities & Exchange Commission via electronic filing
100 F Street, N.E.
Washington, DC 20549
RE: Vanguard Trustees’ Equity Fund
Dear Mr. Thompson:
The following responds to your comments of May 16 and 18, 2011 on the post-effective amendment of the above-referenced registrant (the “Trust”) and its series, Vanguard Emerging Markets Select Stock Fund (the “Fund”). You commented on Post-Effective Amendment Nos. 56 and 57, which were filed on March 28, 2011, and April 15, 2011 pursuant to Rule 485(a).
Comment 1: Prospectus – Fund Summary – Primary Investment Strategies
Comment: You state that the Fund invests mainly in “equity securities of companies located in emerging markets.” Please add disclosure explaining how the Fund determines whether a company is “located in” an emerging market.
Response: We will add the requested disclosure.
Comment 2: Prospectus – Fund Summary – Primary Investment Strategies
Comment: You state that the Fund invests mainly in “equity securities of companies located in emerging markets.” Please add disclosure explaining how the Fund determines whether a particular market is an “emerging market.”
Response: We will add the requested disclosure.
Comment 3: Prospectus – Fund Summary – Primary Investment Strategies
Comment: You state that the Fund will invest at least 80% of its assets in “stocks” of companies located in emerging markets. Please specify the type of stock in which the Fund will invest.
Response: We will add the requested disclosure.