February 28, 2005
U.S. Securities & Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549

RE:  VANGUARD INDEX FUNDS (THE "TRUST")
     FILE NO.  2-56846

Commissioners:

Enclosed is the 95th Post-Effective  Amendment of the Registration  Statement on
Form N-1A for the  Vanguard  Index  Funds  (the  "Trust").  The  purpose of this
Amendment is to: (1) comply with new Form N-1A requirements  concerning policies
related to market  timing,  fair value  pricing,  and  disclosure  of  portfolio
holdings;  (2)  comply  with new Form N-1A  requirements  concerning  disclosure
regarding portfolio managers;  and (3)include a number of non-material editorial
changes.

Pursuant to Rule 485(a) under the  Securities  Act of 1933, we request that this
Amendment be declared  effective on April 29, 2005.  Prior to the effective date
of the  Amendment,  Vanguard will submit a Rule 485(b) filing that will include:
(1) text addressing any SEC staff  comments;  (2) updates to all versions of the
Trust's  prospectus  (this  filing  includes  the  prospectuses  for the  retail
versions  and VIPERs  Shares ); and (3) updated  financial  statements  for each
series of the Trust. Pursuant to Rule 485(d)(2),  Vanguard will request that the
Rule 485(b) filing be declared effective concurrently with this 485(a) filing on
April 29, 2005.

Please contact me at (610) 669-5284 with any questions or comments that you have
concerning the enclosed Amendment.

Sincerely,



Lisa L. Matson
Associate Counsel