P.O. Box 2600
Valley Forge, PA 19482-2600

610-669-7310
lex_smith@vanguard.com

April 20, 2015
Asen Parachkevov, Esq.
U.S. Securities and Exchange Commission		via electronic filing
100 F Street, N.E.
Washington, DC 20549
RE:	Vanguard Index Funds (the “Trust”);
	File No. 2-56846
	Post-Effective Amendment No. 141 – Vanguard Total Stock Market Index Fund (the
	“Fund”)

Dear Mr. Parachkevov,

This letter responds to your comments provided on April 14, 2015, on the above referenced post-effective amendment.

Comment 1:	Prospectus - Fund Summary – Fees and Expenses
Comment:	Please include the Fund’s complete fee table in your response letter.
Response:	Please see the fee table below.
	Annual Fund Operating Expenses
	(Expenses that you pay each year as a percentage of the value of your investment)
		Institutional Shares		Institutional Plus Shares
	Management Fees	0.02	%	0.00	%
	12b-1 Distribution Fee	None		None
	Other Expenses	0.02	%	0.02	%
	Total Annual Fund Operating Expenses	0.04	%	0.02	%
Comment 2:	Prospectus - Fund Summary – Tax Information
Comment:	Please clarify that withdrawals from tax-deferred retirement accounts may be subject to
	taxes.
Response:	We have considered the comment and do not plan to modify the disclosure. We believe
	the current disclosure appropriately conforms to the requirements of Item 7 of Form N-
	1A.

Asen Parachkevov, Esq.
April 20, 2015
Page 2

Comment 3: Tandy Requirements

As required by the SEC, the Fund acknowledges that:

• The Fund is responsible for the adequacy and accuracy of the disclosure in the filing.
• 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.
• 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) 669-7310 with any questions or comments regarding the above response. Thank you.

Sincerely,

/s/ Alexander F. Smith

Alexander F. Smith
Associate Counsel
The Vanguard Group, Inc.