[GRAPHIC OMITTED][GRAPHIC OMITTED]
P.O. Box 2600
Valley Forge, PA 19482-2600
610-503-5693
Natalie_S_Bej@vanguard.com
September 20, 2007
U.S. Securities & Exchange Commission
100 F Street, N.E.
Washington, DC 20549
RE: Vanguard Montgomery Funds (the "Trust")
File Number 333-145624
Commissioners:
Enclosed for filing under the Securities Act of 1933, as amended (the
"Securities Act"), is Pre-Effective Amendment No. 1 to the Trust's Registration
Statement on Form N-14 ("Amendment No. 1"). The purpose of Amendment No. 1 is to
respond to comments provided by Commission staff to the initial filing of the
Registration Statement on August 22, 2007, and to make other minor changes. THE
TRUST HEREBY REQUESTS THAT THE COMMISSION DECLARE AMENDMENT NO. 1 EFFECTIVE AT
9:00 A.M. ON SEPTEMBER 24, 2007 OR AS SOON THEREAFTER AS POSSIBLE.
No filing fee is payable herewith because the Trust is registering an indefinite
amount of shares pursuant to Rule 24f-2 under the Investment Company Act of
1940. Moreover, a fee in connection with the preliminary proxy statement filed
as part of the Registration Statement is not required pursuant to Rule 14a-6(j)
under the Securities Exchange Act of 1934.
The Trust and its distributor, Vanguard Marketing Corporation, have by separate
letter requested, pursuant to Rule 461(a) under the Securities Act, that
Amendment No. 1 be accelerated to an effective date of September 24, 2007. The
request for acceleration is attached to this letter as Appendix A.
We hope the staff finds the revisions in Amendment No. 1 responsive to the
staff's comments on the initial filing of the Registration Statement. Please
contact me at (610) 503 5693 with any questions.
Sincerely,
Natalie S. Bej
Senior Counsel
Enclosures
cc: Christian Sandoe, Esq.
Securities and Exchange Commission
APPENDIX A
461(a) Acceleration Request
September 20, 2007
U.S. Securities & Exchange Commission
100 F Street, N.E.
Washington, DC 20549
RE: Vanguard Montgomery Funds--461(a) Request
for Acceleration of Effectiveness
File Number 333-145624
Commissioners:
Pursuant to Rule 461(a) under the Securities Act of 1933, Vanguard Montgomery
Funds (the "Trust") and its distributor, Vanguard Marketing Corporation,
respectfully request that the effectiveness of Pre-Effective Amendment No. 1 of
the Trust's registration statement on Form N-14 be accelerated to Monday,
September 24, 2007. Pre-Effective Amendment No. 1 addresses comments of the
Commission's staff regarding the initial filing of Form N-14, and has been filed
today, September 20, 2007.
Sincerely,
VANGUARD MONTGOMERY FUNDS
----------------------------------
Name: John J. Brennan (Heidi Stam)*
Title: President
VANGUARD MARKETING CORPORATION, Distributor
----------------------------------
Name: Michael Kimmel
Title: Secretary
cc: Christian Sandoe, Esq.
U.S. Securities and Exchange Commission