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                        [GRAPHIC SHIP LOGO VANGUARD(R)]

 May 20, 2005

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:  Vanguard Specialized Funds
                             File No. 811-3916

Dear Mr. Sandoe:

         The following responds to your comments of May 13, 2005 on the
post-effective amendment of the Vanguard Specialized Funds (the "Registrant")
registration statement on Form N-1A. You commented on PEA number 50 that was
filed on March 30, 2005 pursuant to Rule 485(a). Note that each prospectus page
reference is to the Investor and Admiral Shares versions of the prospectuses.

COMMENT 1:        VANGUARD DIVIDEND GROWTH FUND (PROSPECTUS PAGE 1)
COMMENT: In the  discussion  of  "Investment  Style Risk" in the  Primary  Risks
     section,  there is a reference  to the primary  risk that  "dividend-paying
     large-capitalization  stocks  will trail  returns  from the  overall  stock
     market."  Indicate in the Primary  Investment  Strategies  section that the
     fund invests primarily in large-cap stocks.

RESPONSE: The Divided Growth Fund, as well as the  sector-specific  series funds
     of the Registrant,  do not have specific  market-capitalization  strategies
     and will invest across all  market-capitalization  segments.  They will not
     focus on any  particular  market  segment  at any  particular  time for any
     reason other than to focus on their stated  primary  investment  strategies
     and  objectives.  As  such,  we  believe  that it would  be  misleading  to
     characterize  a  specific  market  cap as a  part  of  the  fund's  primary
     investment strategies. Given that the fund's managers generally do not take
     market  capitalization into account as a portfolio management strategy,  we
     have  removed  the  reference  to  "large-capitalization"  from the  fund's
     Primary Risks section. (See our response to your fourth comment for further
     discussion.)

COMMENT 2:        VANGUARD DIVIDEND GROWTH FUND (PROSPECTUS PAGE 1)
COMMENT: The third sentence of the Primary Investment  Strategies section of the
     prospectus  states,  "[T]hese  stocks  typically--but  not  always--will be
     trading at a discount to the market at the time of purchase."  Clarify what
     the phrase "discount to the market" means.

RESPONSE: We have revised the disclosure as follows to clarify what "discount to
     the  market"  means:  "These  stocks  typically--but  not  always--will  be
     undervalued  relative to the market and will show  potential for increasing
     dividends."

<PAGE>

Christian Sandoe, Esq.
May 20, 2005
Page 2

COMMENT 3A:       VANGUARD ENERGY FUND (PROSPECTUS PAGE 1)
COMMENT:  You  indicated  that you would  like to  "narrow"  the  definition  of
     "energy-related  activities,"  for  purposes  of  defining  what  types  of
     energy-related  securities  are suggested by the Energy Fund's name. To the
     extent applicable, this comment applies to each series of the Registrant.

RESPONSE: As  discussed  in our  response  to comment  3B, we believe  that each
     fund's current  disclosure  complies with Form N-1A and gives  shareholders
     the information  that they need to understand what types of securities each
     fund invests in.

COMMENT 3B:       VANGUARD ENERGY FUND (PROSPECTUS PAGE 1)
COMMENT: You noted that the phrase "such as," as it is used in the Energy Fund's
     Primary  Investment   Strategies  section,   indicates  that  the  list  of
     energy-related activities is not exhaustive.  You also noted that it is not
     clear if "energy  conservation" and "pollution  control" are energy-related
     activities  that  could be  suggested  by the  fund's  name.  To the extent
     applicable, this comment applies to each series of the Registrant.

RESPONSE:  Specific  information about the types of companies in which the funds
     invest is disclosed in both the Primary Investment  Strategies and "More on
     the Funds" sections of each  prospectus.  For example,  the Vanguard Energy
     Fund  prospectus  states  that the fund  invests in  companies  principally
     engaged in energy-related activities such as production and transmission of
     energy  or  energy  fuels;  the  making  of  component  products  for  such
     activities;  energy research; and energy conservation or pollution control.
     The funds'  advisors  neither employ a specific  percentage-of-income  test
     when determining whether a particular company is "principally engaged" in a
     specific industry,  nor are they required to. As you can see by a review of
     the Energy Fund's most recent Statement of Net Assets, far more than 80% of
     the fund's assets are invested in stocks of companies that are "principally
     engaged" in energy-related activities that are disclosed in the prospectus.
     The fund's most recent Statement of Net Assets can be found on EDGAR at the
     following web address:
      www.sec.gov/Archives/edgar/data/734383/000093247105000619/formncsr.htm
     We believe that stocks of companies that are principally  engaged in energy
conservation and pollution control are reasonably related to the types of stocks
suggested by the Energy Fund's name.

COMMENT 4:  VANGUARD ENERGY (PROSPECTUS PAGE 1)
COMMENT:  Disclose the  market-capitalization  strategy of the  Vanguard  Energy
     Fund,  and  disclose  the  specific  risks  of  the   market-capitalization
     strategy. To the extent applicable,  this comment applies to each series of
     the Registrant.

RESPONSE: As noted in our response to your first  comment,  the Vanguard  Energy
     Fund, as well as the sector-specific series funds of the Registrant, do not
     have specific  market-capitalization  strategies and will invest across all
     market  capitalization  segments.  They  will not  focus on any  particular
     market segment at any particular time for any reason other than to focus on
     their stated  primary  investment  strategies and  objectives.  As such, we
     believe that it would be misleading to  characterize a specific  market cap
     as a part of the primary investment strategies,  or a particular market cap
     risk as a primary risk of investing in the funds.  In  actuality,  industry
     concentration,  manager, foreign investment (to the extent applicable), and
     general  stock  market  risk will be the  primary  drivers  of each  fund's
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Christian Sandoe, Esq.
May 20, 2005
Page 3

     performance  relative  to the broad U.S.  stock  market,  not a  particular
     market-cap exposure.
          Furthermore,   we   have   disclosed   each   fund's   median   market
     capitalization. However, investors are ill-served by disclosure of a fund's
     market capitalization range in a prospectus for the following reasons:

                      (1) Market capitalization ranges are subjective over
                  different time periods and among different investment advisors
                  and funds. Defining a particular market capitalization as a
                  specific dollar range could confuse investors because the
                  dollar ranges are so varied over time and among advisors and
                  funds.
                      (2) Ranges change continually because of fluctuations in
                  stock market valuations. Therefore, disclosure of one range in
                  a prospectus could be misleading when the stock market
                  fluctuates.
                      (3) A fund's overall market capitalization range can be
                  very broad1 and not indicative of where the fund's overall
                  market capitalization focus is. The median market
                  capitalization is a more useful piece of information for
                  investors concerned with market capitalization.
                      (4) We believe it is particularly inappropriate to
                  disclose a market capitalization range when a fund does not
                  have a specific investment strategy with respect to market
                  capitalization. The Vanguard Energy and Precious Metals and
                  Mining Funds, for example, have investment strategies that
                  focus on particular industries and not on particular market
                  capitalization ranges. We believe that disclosure of the
                  market capitalization range would draw undue attention to a
                  fund characteristic that is not generally considered by the
                  advisor. Indeed, such disclosure could cause investors to
                  believe that a company's market capitalization plays a
                  significant role in the advisor's decision to buy or sell the
                  company stock, when this is not the case.
                      (5) Form N-1A does not require funds to disclose specific
                  market capitalization dollar ranges, particularly when a fund
                  has no particular strategy or policy with respect to them.
                           In future filings we will, if appropriate, move the
                  market capitalization disclosure out of the prospectus, or to
                  a section of the prospectus that does not indicate that it is
                  a principal strategy.

COMMENT 5:        VANGUARD ENERGY FUND (PROSPECTUS PAGE 10)
COMMENT: In the disclosure  concerning the Vanguard Energy Fund's policy against
     frequent  trading  and market  timing,  there is the  following  statement,
     "Certain  Vanguard funds charge  shareholders  purchase  and/or  redemption
     fees." Disclose the circumstances in which the fees will not be imposed, as
     required by Form N-1A (no item specified).  To the extent applicable,  this
     comment applies to each series of the Registrant.

RESPONSE: The  following  disclosure  is already  included in the  discussion of
     redemption fees in the "Investing With Vanguard" section of the prospectus,
     pursuant to Item 6 of Form N-1A:

     Redemption fees may not apply to certain categories of redemptions, such as
     those that Vanguard reasonably  believes may not raise  frequent-trading or
     market-timing  concerns.   These  categories  are:  redemptions  of  shares
     purchased   through  the   reinvestment   of  dividend  and  capital  gains
     distributions; redemptions resulting from account transfers and share class
     conversions   within   the   same   fund;   redemptions   from  or   within
     employer-
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Christian Sandoe, Esq.
May 20, 2005
Page 4

     sponsored   defined  contribution  plans  serviced  by  Vanguard's
     Integrated    Retirement   Plan   Solutions   Department   and   Vanguard's
     Institutional Investment Group; redemptions resulting from required minimum
     distributions  from an  individual  retirement  account for which  Vanguard
     serves as trustee  or  custodian;  redemptions  resulting  from  individual
     retirement   account   conversions,    recharacterizations,    and   excess
     contributions;  redemptions  within  Vanguard  advisory  programs  (such as
     Vanguard  Fiduciary  Services)  and  institutional  rebalancing  and  asset
     allocation programs;  redemptions from or within annuity programs for which
     Vanguard  provides   specialized   marketing  or  support   services;   and
     redemptions  by certain  pension  plans as required by law or by regulatory
     authorities.  Redemption  fees  also  may be  waived  if  required  by law,
     regulation, or court order.

     Certain intermediaries might not exempt redemption fees as described above.
     Please  also see  Other  Rules You  Should  Know--Investing  With  Vanguard
     Through Other Firms regarding accounts held through intermediaries.

                  INVESTING WITH VANGUARD THROUGH OTHER FIRMS
                  You may purchase or sell Investor Shares of most Vanguard
                  funds through a financial intermediary, such as a bank,
                  broker, or investment advisor. HOWEVER, ACCESS TO ADMIRAL
                  SHARES THROUGH A FINANCIAL INTERMEDIARY IS RESTRICTED. PLEASE
                  CONSULT YOUR FINANCIAL INTERMEDIARY TO DETERMINE WHETHER
                  ADMIRAL SHARES ARE AVAILABLE THROUGH THAT FIRM.

     When  intermediaries  establish  omnibus accounts in the Vanguard funds for
     their clients,  we cannot monitor the individual clients' trading activity.
     However,  we review trading  activity at the omnibus account level,  and we
     look  for  activity  that  may  indicate   potential  frequent  trading  or
     market-timing.  If we detect suspicious trading activity,  we will seek the
     assistance of the  intermediary  to investigate  that trading  activity and
     take appropriate action, including prohibiting additional purchases of fund
     shares by a client. Intermediaries may apply frequent-trading policies that
     differ from those described in this prospectus. If you invest with Vanguard
     through  an  intermediary,   please  read  that  firm's  program  materials
     carefully to learn of any rules or fees that may apply.

COMMENT 6:        VANGUARD ENERGY FUND (PROSPECTUS PAGE 11)
COMMENT: The prospectus  indicates that a discussion  about the board's approval
     of the fund's  investment  advisory  agreement  is  included  in the fund's
     report to  shareholders  covering the period from February 1, 2005, to July
     31, 2005. This prospectus will be effective before the report is available,
     so indicate that the report is not yet available. To the extent applicable,
     this comment applies to each series of the Registrant.

RESPONSE: We will add the following sentence to the new disclosure:  "The report
     will be available within 60 days after July 31, 2005."

COMMENT 7:        VANGUARD ENERGY FUND (PROSPECTUS PAGE 12)
COMMENT: In the  discussion of the Vanguard  Energy Fund's  investment  advisor,
     there are two portfolio  managers  listed.  Indicate the separate  roles of
     each portfolio manager.  To the extent applicable,  this comment applies to
     each series of the Registrant.
<PAGE>
Christian Sandoe, Esq.
May 20, 2005
Page 5

RESPONSE:  This comment only applies to the Energy Fund,  and the Energy  Fund's
     current  disclosure  complies with the requirements of Item 5 of Form N-1A.
     The prospectus currently describes Karl Bandtel as the fund's manager since
     2002,  and James  Bevilacqua  as a fund manager  involved in the  portfolio
     management and securities analysis of the fund since 1998.

COMMENT 8:        EACH SERIES OF THE REGISTRANT
COMMENT: To the extent applicable, the same comments apply to each series of the
     Registrant.

RESPONSE:  To the extent  applicable,  we have  considered  comments 1 through 7
     above with respect to each series of the Registrant.

COMMENT 9:        VANGUARD PRECIOUS METALS AND MINING FUND
COMMENT: Given the Fund's  propensity  to invest in emerging  markets,  disclose
     emerging  markets  risk for the Fund in the  Primary  Risks  section of the
     prospectus.

RESPONSE: The following risk disclosure is included in the Primary Risks section
     of the prospectus, "The Fund is subject to ... Emerging markets risk, which
     is the  chance  that,  to the extent  the Fund  invests in them,  stocks of
     emerging markets could be substantially  more volatile,  and  substantially
     less liquid, than the stocks of more developed foreign markets."

COMMENT 10:       VANGUARD PRECIOUS METALS AND MINING FUND (SAI PAGE B-34)
COMMENT:  The   disclosure   concer