[SHIP LOGO][Vanguard/(R)/ Logo]
P.O. Box 2600
Valley Forge, PA 19482-2600
610-669-2689
nathan_m_will@vanguard.com
November 16, 2007
Christian Sandoe, Esq.
U.S. Securities & Exchange Commission VIA ELECTRONIC FILING
100 F Street, N.E.
Washington, DC 20549
RE: VANGUARD WORLD FUND
Dear Mr. Sandoe,
The following responds to your comments of November 9, 2007 on the
post-effective amendment of the registration statement of the above-referenced
registrant. You commented on Post-Effective Amendment No. 107 that was filed on
September 24, 2007.
COMMENT 1: PROSPECTUS - DEFINITION OF MEGA CAP STOCKS
- ------------------------------------------------------------
Comment: Please include a more detailed definition of "Mega Cap"
stocks. Consider including a market-capitalization range
of the Funds' target benchmarks and establishing an 80% policy
for the Funds.
Response: We consider Mega Cap, Mega Cap Growth, and Mega Cap Value
stocks to be those stocks identified by MSCI as the largest
300 names by market capitalization in the U.S. Equity market.
These "largest-cap" stocks comprise the respective benchmark
indexes of each Fund. As currently disclosed in the Funds'
prospectus, each Fund seeks to track its target index, and
attempts to replicate that index by investing "all, or
substantially all," of its assets in the stocks that make up
the index. Form N-1A does not specifically require that a
market capitalization range be part of a fund's primary
investment strategy, and the Funds already disclose that they
will invest at least 80% of their assets in the stocks that
make up their target indices. After consideration of this
comment, we do not plan to revise the disclosure.
COMMENT 2: PROSPECTUS - ASSETS UNDER MANAGEMENT
- ------------------------------------------------------
Comment: Please revise the assets under management figures appearing
under "The Funds and Vanguard" and "Investment Advisor" so
that they are consistent.
Response: The $1 trillion figure appearing under "The Funds and
Vanguard" represents the aggregate amount of assets held by
the 145 funds of The Vanguard Group. The figure appearing
under "Investment Advisor" represents the subset of that $1
trillion of assets managed internally by Vanguard's
Quantitative Equity and Fixed Income Groups. The balance of
the assets is
Christian Sandoe, Esq.
November 16, 2007
Page 2
managed by external advisors. Accordingly, we do not plan to
revise the disclosure so that both figures are consistent.
COMMENT 3: SAI - INVESTMENT LIMITATIONS: ALL FUNDS
Comment: Please add disclosure indicating that (i) compliance with the
Funds' investment limitations, except for borrowing, is
measured at the time securities are purchased, and (ii) any
borrowing in excess of the limits imposed by Section 18 of the
1940 Act must be reduced to such limits within three days
(excluding Sundays and holidays).
Response: We have modified the disclosure as follows (additions appear
as underlined text):
"Compliance with the investment limitations set forth above is
generally measured at the time the securities are purchased.
Unless otherwise required by the 1940 Act, if a percentage
restriction is adhered to at the time the investment is made,
a later change in percentage resulting from a change in the
market value of assets will not constitute a violation of such
restriction. All investment limitations must comply with
applicable regulatory requirements. For more details, see
"Investment Policies."
COMMENT 4: SAI - INVESTMENT ADVISORY SERVICES: SCHRODER INVESTMENT
MANAGEMENT NORTH AMERICA, INC.: DESCRIPTION OF COMPENSATION
- -----------------------------------------------------------------------------
Comment: Please list the relevant benchmarks against which Schroders
assesses the performance of an individual fund manager.
Response: The relevant benchmarks against which Schroders assesses the
performance of an individual fund manager will change
depending on the specific mandate of the fund. For example,
the performance of the individual fund managers of the
Schroders portfolio of the Vanguard International Growth Fund
would be measured against the MSCI EAFE Index, the performance
benchmark of the Fund. Accordingly, we do not plan to revise
the disclosure.
Christian Sandoe, Esq.
November 16, 2007
Page 3
COMMENT: TANDY REQUIREMENTS
- ------------------------------------
As required by the SEC, the Funds acknowledge that:
o The Fund is responsible for the adequacy and accuracy of the
disclosure in the filing.
o 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.
o 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) 669-2689 with any questions or comments
regarding the above responses. Thank you.
Sincerely,
Nathan M. Will
Associate Counsel
Securities Regulation, Legal Department