[SHIP LOGO VANGUARD(R)]
P.O. Box 2600
Valley Forge, PA 19482-2600
610-669-1538
Judy_L_Gaines@vanguard.com
August 14, 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
Dear Mr. Sandoe,
The following summarizes my discussion with Brion Thompson yesterday
afternoon regarding your comments to Post-effective Amendment No. 60 of Vanguard
International Equity Index Funds' registration statement. The Post-Effective
Amendment was filed on June 26, 2008.
Comment 1: Prospectus - Turnover Rate
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Comment: Disclosure of comparable funds' peer group turnover rates is
not presented in close proximity to the turnover rates of the
Vanguard funds. The relevance of the peer group information is
of less relevance based on its current location in the
prospectus.
Response: We have reviewed our disclosure and we think the information
is relevant in its current location in the prospectus. Since
there is no requirement that the peer group turnover
information be placed in any particular proximity to fund
turnover information, we don't plan to move the turnover rate
discussion and/or the accompanying Plan Talk box.
Comment 2: Prospectus - The Fund and Vanguard and Investment Advisor
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Comment: In the section entitled "The Fund and Vanguard" the prospectus
says the Vanguard funds hold assets in excess of $1.2
trillion. In the section entitled "Investment Advisor" the
prospectus says Vanguard serves as advisor for approximately
$1 trillion. Please explain this apparent inconsistency.
Response: The two figures represent different things, and both are
accurate. The first figure, $1.2 trillion, represents the
assets held by all of the Vanguard funds, including funds
managed internally as well as funds managed by external
investment advisors. The second figure, "approximately $1
trillion," represents the assets under management of
Vanguard's internally managed funds - those managed by
Vanguard's Fixed Income Group and Vanguard's Quantitative
Equity Group, but not including external investment advisers.
Accordingly, we do not plan to amend the disclosure.
Comment 3: Continued Use of Prospectus Supplement from February with an
Updated Prospectus Dated August 2008
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Comment: It is improper to continue to use a prospectus supplement
dated as of February 2008 with a prospectus that is being
updated via a 485(a) filing and which will be dated August
2008.
Christian Sandoe, Esq.
August 19, 2008
Page 2
Response: We agree with the comment, and will discontinue use of the
supplement. This will be reflected in our 485(b) filing
that responds to these comments, where the supplement will no
longer appear.
Comment 4: Emerging Markets Fund - Item 2 Performance Table
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Comment: In compliance with the requirements of Item 2(c)(2)(i) of Form
N-1A, please show the performance of a broad-based securities
index for the same periods of time as the performance of the
fund, itself.
Response: We will edit the performance table as requested.
Comment 5: Page 7 of Signal Shares Prospectus
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Comment: In the operating expense table, pursuant to Instruction 1(a)
to Item 3 of Form N-1A, please round all percentages to the
nearest hundredth of one percent.
Response: We will round the percentages as requested.
Comment 6: Tandy Requirements
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As required by the SEC, the Funds acknowledge that:
o The Funds are 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 Funds 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) 669-1538 with any questions or comments
regarding the above responses. Thank you.
Sincerely,
Judith L. Gaines
Associate Counsel
Securities Regulation, Legal Department