February 1, 2010
Christian Sandoe, Esq.
U.S. Securities & Exchange Commission via electronic filing
100 F Street, N.E.
Washington, DC 20549
RE: Vanguard Explorer Fund
Dear Mr. Sandoe,
The following responds to your comments of January 29, 2010 on the post-effective amendment of the registration statement of the above-referenced registrant. You commented on Post-Effective Amendment No. 86 that was filed on December 16, 2009 pursuant to Rule 485(a).
Comment 1: Prospectus—Annual Total Returns
Comment: In the average annual total returns table, please include the Fund’s Admiral Share since inception date and performance in the table rather than in a footnote to the table.
Response: We will include the since-inception date and performance for Admiral Shares in the table rather than in a footnote.
As required by the SEC, each Fund acknowledges that:
· The Fund is responsible for the adequacy and accuracy of the disclosure in the filing.
· Staff comments or changes in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing.
· The Fund may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Please contact me at (610) 669-4294 with any questions or comments regarding the above responses. Thank you.
Sincerely,
Michael J. Drayo
Associate Counsel
