SecProbe.io

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>horizoncorresp.txt
<DESCRIPTION>HORIZON CORRESPONDENCE
<TEXT>

                                   [SHIP LOGO]
                        [THE VANGUARD GROUP, INC. /(R)/]

December 2, 2004

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 Horizon Funds

Dear Mr. Sandoe:

     The  following  responds  to  your  comments  of  December  1,  2004 on the
post-effective  amendment  of the  registration  statement  of Vanguard  Horizon
Funds.  You  commented on PEA 19 that was filed on October 21, 2004  pursuant to
Rule 485(a).  All of your comments  pertained to Vanguard  Global Equity Fund, a
series of Vanguard Horizon Funds.

COMMENT 1:  PROSPECTUS - PRIMARY RISKS

Comment:          The risk of investing  in small- and mid-cap  stocks is
                  included in the primary risk section,  but capitalization is
                  not part of the Fund's primary investment strategy.
Response:         The  Fund  does  not  have a  primary  strategy  of  focusing
                  on any particular  capitalization  range.  In response to
                  Item 4, we indicate that the Fund has a secondary,  or
                  non-primary,  strategy of investing in small- and  mid-cap
                  stocks.  Accordingly,  we do  not  plan  to add  any  Primary
                  Investment Strategy disclosure in response to Item 2 of
                  Form N-1A regarding market  capitalization.  We will leave the
                  Primary Risk  section  unchanged since, to the extent that the
                  Fund holds small- and mid-cap stocks, we want investors to
                  understand the related risks.

COMMENT 2: PROSPECTUS - ANNUAL TOTAL RETURN BAR CHART

Comment:          Include the most recent calendar quarter's returns in a
                  footnote to the annual total return table.

Response:         Since the bar chart will include returns as of 12/31/2004, and
                  since the prospectus will be in print as of January 2004,
                  there will not be a footnote with return information. The
                  12/31/2004 returns will represent the most recently ended
                  calendar quarter.

Comment 3:        Prospectus - Average Annual Total Return Table
Comment:          Should the table cover the periods ended December 31, 2003
                  rather than 2004?

Response:         As we discussed on the phone, following our October 21st
                  485(a) filing, Vanguard Horizon Funds filed a second 485(a)
                  filing on November 24, 2004 ("PEA 20") for effectiveness on
                  January 25, 2005. PEA 20 supersedes PEA 19. Given PEA 20's
                  2005 print date, the table should cover periods ended December
                  31, 2004.

COMMENT 4: - PROSPECTUS - MARKET EXPOSURE
Comment:          Does the Fund comply with footnote 42 of the Names Rule
                  release as it pertains to use of the term "Global" in a fund
                  name?

Response:         Yes.  As the footnote contemplates, the Fund invests its
                  assets in investments that are tied economically to a
                  number of countries throughout the world.

Comment 5: - Prospectus - Market Exposure
Comment:          There is a risk flag discussing small- and mid-cap risk, but
                  capitalization is not part of the Fund's primary strategy.

Response:         See response to Comment 1.

COMMENT 6: - PROSPECTUS - MARKET EXPOSURE
Comment:          Rather than the asset-weighted median market capitalization of
                  the Fund, you would like us to state the market capitalization
                  range for the Fund.

Response:         We have disclosed the Fund's median market capitalization.
                  However, we do not plan to include the market capitalization
                  range since investors are ill served by such disclosure 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 broad 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) Form N-1A does not require funds to disclose specific
                  market capitalization dollar ranges.

COMMENT 7: - PROSPECTUS - SECURITY SELECTION

Comment:          By "secondary" strategy, do we mean "not principal?"

Response:         Yes.

COMMENT 8: - PROSPECTUS - CASH MANAGEMENT
Comment:          In the Cash Management section, Vanguard CMT Funds are
                  described as funds "established under an SEC exemption." The
                  funds were not established by the exemption; rather the use of
                  the funds by other affiliated funds was permitted by an SEC
                  exemption. Clarify this language.

Response:         This disclosure has been corrected in PEA 20.

COMMENT 9: - PROSPECTUS - EXCHANGING SHARES
Comment:          The new market-timing rules require disclosure that includes
                  any specific circumstances under which we would waive our
                  market timing policies.

Response:         We disclose these circumstances on page 22 in the Exchanging
                  Shares section of both PEA 19 and PEA 20.

COMMENT 10: - PROSPECTUS - INVESTING WITH VANGUARD THROUGH OTHER FIRMS
Comment:          We state, "If we detect suspicious trading activity, we will
                  seek the assistance of the intermediary to investigate
                  that trading activity and take appropriate action."
                  What do we mean by "take appropriate action?"

Response:         What constitutes "taking appropriate action" is a facts and
                  circumstances determination that depends on several factors
                  including who the intermediary is and what its policies are,
                  what type of trading activity has transpired, and how those
                  policies apply to that activity. Given all the possible
                  permutations, we think the best way to serve shareholders is
                  to keep the disclosure as it is currently worded.

COMMENT 11: - SAI - DESCRIPTION OF MARATHON ASSET MANAGEMENT LLP
Comment:          Include the past three years of advisory fees payable to
                  Marathon.

Response:         The Fund changed its fiscal year end from October 31 to
                  September 30 effective September 30, 2004. Accordingly, the
                  SAI in PEA 20 includes the advisory fees payable to Marathon
                  for the fiscal years ended October 31, 2002 and 2003, and the
                  new fiscal year (which we refer to as a fiscal period since it
                  was a year that consisted of less than 12 months) ended
                  September 30, 2004.

COMMENT 12: - SAI - BOARD REVIEW OF INVESTMENT ADVISORY ARRANGEMENTS
Comment:          Add disclosure to the SAI that relates the factors considered
                  by the Fund's board of trustees in reviewing investment
                  advisory agreements to the particulars of the Fund, pursuant
                  to Item 13(b)(10) of Form N-1A.

Response:         This has been addressed in PEA 20.

COMMENT 13:       TANDY REQUIREMENTS
Comment:          The SEC is now requiring all registrants to provide at the end
                  of response letters to registration statement comments, the
                  following statements:

               o    The Fund is 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 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.

Response:         As required by the SEC, we will provide the foregoing
                  acknowledgements.

                                * * * * *

              As required by the SEC, the Fund acknowledges that:

               o    The Fund is 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 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) 669-1538 with any questions or comments
regarding the above responses. Thank you.

Sincerely,

Judith L. Gaines
Associate Counsel

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