[SHIP LOGO VANGUARD(R)]
P.O.Box 2600
Valley Forge, PA 19482-2600
610-669-4294
Michael_Drayo@vanguard.com
June 2, 2008
Christian Sandoe, Esq.
U.S. Securities & Exchange Commission via electronic filing
100 F Street, N.E.
Washington, DC 20549
RE: Vanguard International Equity Index Funds
File No. 33-32548
Dear Mr. Sandoe,
This letter responds to your May 19, 2008 comments on Post-Effective Amendment
No. 58 of the above-referenced registrant that was filed on April 18, 2008.
Comment 1: Prospectus - Fund Profile Vanguard Total World Stock Index
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Fund (the "Fund")
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Comment: What percentage of Fund's assets will be invested in
securities of issuers located in emerging markets? Depending
on that percentage, consider removing emerging markets risk
disclosure if the percentage is very low.
Response: We expect that emerging markets securities will comprise more
than 10% of the FTSE All-World Index, the Fund's index. As a
result, we intend to include emerging markets risk disclosure
in the Fund's prospectus.
Comment 2: Prospectus - Assets Under Management
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Comment: Please revise the assets under management figures appearing
under "The Fund and Vanguard" and "Investment Advisor" so that
they are consistent.
Response: The $1.2 trillion figure appearing under "The Fund and
Vanguard" represents the aggregate amount of assets held by
the 150 funds of comprising the Vanguard family of funds. The
figure appearing under "Investment Advisor" represents the
subset of that $1.2 trillion of assets managed internally by
Vanguard's Quantitative Equity and Fixed Income Groups. The
balance of the assets is managed by external advisors.
Accordingly, we do not plan to revise the disclosure so that
both figures are consistent.
Christian Sandoe, Esq.
June 2, 2008
Page 2
Comment 3: SAI - Disclosure of Industry Concentration Policy
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Comment: Clarify the Fund's fundamental investment limitation on
industry concentration to make it clear that if the index that
the Fund seeks to track becomes concentrated in a particular
industry, then the Fund too will become concentrated in that
particular industry.
Response: If the Fund's target index becomes concentrated in a
particular industry, then the Fund will seek to track the
index, and as a result become concentrated in that industry.
We believe that the currently drafted fundamental policy makes
it clear that the Fund will concentrate in a particular
industry if the Fund's index becomes concentrated in
securities of issuers in a particular industry.
Comment 4: Tandy Requirements
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As required by the SEC, the Fund acknowledges 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 610-669-4294 with any questions or comments regarding the
above responses. Thank you.
Sincerely,
Michael J. Drayo
Associate Counsel
The Vanguard Group
Securities Regulation, Legal Department