[GRAPHIC OMITTED][VANGUARD LOGO] P.O.Box 2600 Valley Forge, PA 19482-2600 610-669-5284 Lisa_Matson@vanguard.com November 17, 2006 Christian Sandoe, Esq. Division of Investment Management U.S. Securities and Exchange Commission VIA ELECTRONIC FILING 450 Fifth Street, N.W., Fifth Floor Washington, D.C. 20549 Re: Request for 485(b)(1)(vii) Filing for the Addition of Signal Shares Class Disclosure -------------------------------------------------------------------------------- Dear Mr. Sandoe: As discussed with you on an informal basis on July 18, 2006, Vanguard intends to add a Signal Shares class to the following Vanguard funds: 1. Vanguard PRIMECAP Fund (a series of Vanguard Chester Funds) 2. Vanguard Capital Opportunity Fund (a series of Vanguard Horizon Funds) 3. Vanguard Morgan Growth Fund 4. Vanguard Growth & Income Fund (a series of Vanguard Quantitative Funds) 5. Vanguard Wellesley Income Fund 6. Vanguard Equity Income Fund (a series of Vanguard Fenway Funds) Each Registrant intends to file updated Registration Statements on or before January 24, 2007. As internal counsel to the Registrants and their series indicated above (the "Funds") and pursuant to Rule 485(b)(1)(vii) under the Securities Act of 1933, I hereby request permission to file post-effective amendments to the Registrants' Registration Statements under this paragraph that includes new disclosure regarding the Signal Shares class. The Signal Shares disclosure that will be added to the Registration Statements for the Funds is identical (except for the specific expense ratios) to the disclosure contained in the registration statement that was filed pursuant to Rule 485(a) on June 2, 2006 for Vanguard Balanced Index Fund, Post-Effective Amendment No. 30 (the "Balanced Registration Statement"), which was reviewed and commented on by the Staff. The Registrants represent that all other disclosure contained in the proposed filings has been previously filed or is otherwise consistent with the requirements of Rule 485(b). Therefore, the Registrants certify that the new disclosure regarding the Funds' Signal Share class is the same as the Signal Share class disclosure contained in the Balanced Registration Statement, and that all other disclosure contained in the filing is otherwise eligible to become effective under paragraph (b) under Rule 485. Christian Sandoe, Esq. November 16, 2006 Page 2 I would appreciate your response on or before January 17, 2007. We intend to file post-effective amendments for the Registrants on or before January 24, 2007. If you have any questions or comments with respect to this request, please call me at (610) 669-5284. Sincerely, /s/ Lisa Matson Lisa Matson Associate Counsel Securities Regulation, Legal Department cc: Michael Lainoff Assistant Director Division of Investment Management Brion Thompson Division of Investment Management