| December 24, 2015 | ||
| Asen Parachkevov, Esq. | ||
| U.S. Securities and Exchange Commission | via electronic filing | |
| 100 F Street, N.E. | ||
| Washington, DC 20549 | ||
| RE: | Vanguard International Equity Index Funds (the “Trust”) | |
| File No. 33-32548 | ||
| Post-Effective Amendment Number 103 | ||
Dear Mr. Parachkevov,
This letter responds to your comments provided on December 18, 2015, on the above referenced post-effective amendment. The comments apply to Vanguard European Stock Index Fund, Vanguard Pacific Stock Index Fund, and Vanguard Emerging Markets Stock Index Fund.
| Comment 1: | Prospectus |
| Comment: | Please confirm that the subsequent post-effective amendment will include |
| conforming content changes for all share classes offered by each Fund as | |
| this post-effective amendment only included Investor Shares and Admiral | |
| Shares. | |
| Response: | The updated prospectuses for the other share classes of each Fund will be |
| included in a 485(b) filing prior to the effective date. | |
| Comment 2: | Prospectus – Fund Summary |
| Comment: | Pursuant to Item 4 of Form N-1A, please consider including information |
| about the spliced index in the narrative explanation accompanying the bar | |
| chart and table for each Fund. | |
| Response: | In response to staff comments received in August 2010, the definition of the |
| spliced index was removed from the Item 4 disclosure. In response to your | |
| comments, we will restore these descriptions as responsive to Item 4, | |
| Instruction 2 (b) in the subsequent post-effective amendment. | |
| Comment 3: | Prospectus – Vanguard Emerging Markets Stock Index Fund |
| Comment: | Please provide the rationale for using a transition index for the Fund rather than |
| moving right to the new target benchmark. | |
| Response: | As described in the initial notice and prospectus supplement, the Fund’s Board |
| approved the use of a transition index in order to enable the Emerging Markets | |
| Stock Index Fund’s advisor, The Vanguard Group, Inc., to make the necessary | |
| adjustments to portfolio holdings in a manner that minimizes impact to Fund | |
| shareholders. The transition index will gradually increase exposure to China A- | |
| shares and small-capitalization equity securities while proportionately reducing | |
| exposure to other stocks based on their weightings in the new target index. | |
| Comment 4: | Prospectus – More on the Fund |
| Comment: | Please confirm that the derivatives investments listed in this section are not |
| part of the Funds’ principal investment strategies. | |
| Response: | We have reviewed the disclosure and can confirm that derivatives investments |
| are not part of the Funds’ principal investment strategies. | |
| Comment 5: | SAI – China A-shares Risk |
| Comment: | Please confirm that you have considered the appropriate disclosure of the risks |
| associated with the recent market events in China when trading was halted by | |
| numerous China A-shares issuers. | |
| Response: | We considered the risks associated with the recent market events and |
| determined that because this risk is generally heightened in other foreign | |
| markets, not only in China, it is appropriately disclosed in the description of | |
| Foreign Securities. Additionally, given the percentage of China A-shares | |
| included in the new target benchmark (approximately 6% as of September 30, | |
| 2015) it was determined that this and other settlement risks unique to China A- | |
| shares are appropriately disclosed in the statement of additional information. | |
| Comment 6: | Tandy Requirements |
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) 669-8439 with any questions or comments regarding the above response. Thank you.
Sincerely,
Christyn L. Rossman
Associate Counsel
The Vanguard Group, Inc.