P.O. Box 2600
Valley Forge, PA 19482-2600
610-669-2689
Frances_T_Han @vanguard.com
November 14, 2011
Chad Eskildsen, Esq.
U.S. Securities & Exchange Commission via electronic filing
100 F Street, N.E.
Washington, DC 20549
RE: Vanguard Star Funds; File No. 2-88373
Dear Mr. Eskildsen:
The following responds to your comments of November 9, 2011 on the Post-Effective Amendment No. 67 of the above-referenced registrant that was filed on September 30, 2011 pursuant to Rule 485(a). The following comments pertain to Vanguard LifeStrategy Income Fund, Vanguard LifeStrategy Conservative Growth Fund, Vanguard LifeStrategy Moderate Growth Fund, and Vanguard LifeStrategy Growth Fund, each a series of the registrant.
Comment 1: Prospectus: Fund Summary – Tax Information
Comment: In the “Tax Information” sections of the Prospectus for each Fund, please delete the text following the first sentence, as it is not required by Form N-1A.
Response: We will remove the text following the first sentence of the “Tax Information” section for each Fund.
Comment 2: SAI: Financial Statements
Comment: On page B-70, the date of financial statements for the LifeStrategy Funds should refer to the Funds’ semi-annual period, not the fiscal year end.
Response: We will update the date to refer to the LifeStrategy Funds’ financial statements for the fiscal period ended April 30, 2011.
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Chad Eskildsen, Esq.
November 14, 2011
Page 2
Tandy Requirements
As required by the SEC, the 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) 503-5804 with any questions or comments regarding the above responses.
Sincerely,
Frances T. Han
Associate Counsel
The Vanguard Group, Inc.
cc: Brion Thompson, Esq.
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