[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