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                            April 24, 2023

       Jason Dubinsky
       Chief Financial Officer
       Morningstar, Inc.
       22 West Washington Street
       Chicago, IL 60602

                                                        Re: Morningstar, Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2022
                                                            Filed February 24,
2023
                                                            File No. 000-51280

       Dear Jason Dubinsky:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments. In some of our comments, we
may ask you to
       provide us with information so we may better understand your disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for the Fiscal Year Ended December 31, 2022

       Notes to Consolidated Financial Statements
       6. Segment and Geographical Area Information, page 93

   1.                                                   We note your previous
response to comment 1 in your letter dated June 10, 2020
                                                        regarding your
determination that the Company has a single operating and reportable
                                                        segment, and that you
continue to identify a single reportable segment. We also note your
                                                        current disclosure on
page 11 regarding your license-based, asset-based, and transaction-
                                                        based product areas,
which each still represent more than 10% of your total revenues,
                                                        and your continued
discussion of these product areas, including on a relative margin and
                                                        directional basis, in
your investor questions and answers provided on Forms 8-K, such as
                                                        those filed on July 22,
2022, September 23, 2022 and March 23, 2023. Given your
                                                        continued and ongoing
discussion of these product areas, please provide us with an
                                                        updated ASC 280 segment
identification analysis, including information on the following:
                                                            Provide us with
details on your current management structure and how your
 Jason Dubinsky
Morningstar, Inc.
April 24, 2023
Page 2
              Company is organized, including an organizational chart.
                Describe the role of your CODM and each of the individuals
reporting to the CODM.
                Identify and describe the role of each of your product area
managers and leadership
              team.
                Describe the key operating decisions, who makes these
decisions, how performance
              is assessed and how resources are allocated within your business.
                Tell us how often the CODM meets with his direct reports and
product area
              managers, the financial information the CODM reviews in
conjunction with those
              meetings and the other participants at those meetings.
                Explain how budgets are prepared, who approves the budget at
each step of the
              process, the level of detail discussed at each step, and the
level at which the CODM
              makes changes to the budget.
                Describe the basis for determining the compensation for each
individual that reports
              to the CODM.
2.       As part of your updated segment identification analysis, describe the
financial information
         reviewed by the CODM for the purpose of allocating resources and
assessing
         performance. In this regard, your previous response indicated that a
variety of financial
         information, including by product area, is provided to and reviewed by
the CODM, and
         that the CODM meets with product area leaders on a regular basis to
review performance
         in order to track progress across key business objectives. We also
note certain
         disaggregated financial information, including relative margin and
directional margin
         impacts, is available based on your responses to investor questions
and answers. Please
         tell us whether the CODM continues to receive disaggregated financial
information, such
         as by product or product area, and, if so, describe it in detail, how
frequently it is
         provided, and how it is used by the CODM. In addition, describe the
key business
         objectives that are tracked and discussed with the product area
leaders, as referenced in
         your previous response letter. Finally, describe the financial
information provided to the
         Board of Directors and how frequently that information is reviewed.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Cara Lubit at 202-551-5909 or Marc Thomas at
202-551-3452 with any
questions.



FirstName LastNameJason Dubinsky                              Sincerely,
Comapany NameMorningstar, Inc.
                                                              Division of
Corporation Finance
April 24, 2023 Page 2                                         Office of Finance
FirstName LastName