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                               November 17, 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
                                                            Response dated
November 9, 2023
                                                            File No. 000-51280

       Dear Jason Dubinsky:

              We have reviewed your November 9, 2023 response to our comment
letter and have the
       following comments.

              Please respond to this letter 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 a
       comment applies to your facts and circumstances, please tell us why in
your response.

               After reviewing your response to this letter, we may have
additional comments. Unless
       we note otherwise, any references to prior comments are to comments in
our [Month day, year]
       letter.

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

       6. Segment and Geographical Area Information, page 93

   1.                                                   We note from your
response that you have chosen Adjusted Operating Income as the
                                                        reported measure of
profit or loss for your segments. Please (i) provide us with a list of all
                                                        measures of profit or
loss at the product area level that are provided to the CODM; (ii)
                                                        describe each of these
measures; (iii) tell us the frequency with which they are provided;
                                                        and (iv) tell us how
you concluded that Adjusted Operating Income was the measure
                                                        required to be
disclosed under ASC 280-10-50-28. As examples only, your most recent
                                                        response references
operating profit (page 3), and page 13 of your response dated May 31,
                                                        2023 references
operating income before central cost allocations, EBITDA including
                                                        central cost
allocations, EBITDA excluding central cost allocations, operating income,
                                                        and operating margin.
   2.                                                   We note that page 4 of
your response says the CODM will use Adjusted Operating
 Jason Dubinsky
Morningstar, Inc.
November 17, 2023
Page 2
         Income to make decisions to allocate resources and assess performance
of segments.
         Please clarify whether Adjusted Operating Income at the product area
level was used by
         the CODM during the quarter ended September 30, 2023 and in prior
periods, or whether
         this is a measure that has not historically been used but will be used
going forward.
3.       We continue to evaluate your response, including the qualitative
factors considered in
         your aggregation analysis, and may have further comments. However, in
consideration of
         your aggregation conclusion, please provide us with the underlying
historical financial
         and other data you considered in concluding that the aggregated
segments have similar
         economic characteristics under ASC 280-10-50-11. As part of your
response, please
         provide quantitative data for revenues and the measures of segment
profitability you
         considered, by year, for each operating segment.
4.       We note from your response that you project that Morningstar
Sustainalytics    current
         margin is below that of Enterprise and PitchBook, however, you project
it will achieve
         similar long-term margins. Similarly, you project margin convergence
for the three
         operating segments in Asset and Index Solutions. Please clarify
whether and how you
         considered and determined actual margins achieved, in addition to the
ability to achieve
         similar long-term margins, when evaluating your segments for
aggregation. Please also
         provide us with quantitative details regarding (i) actual historical
individual (not
         aggregated) segment revenues and margins; (ii) assumptions underlying
your projections
         for margin convergence among different businesses, as well as when you
expect such
         convergence to actually occur, and (iii) whether the segments you
aggregated are expected
         to have similar long-term sales trends and the assumptions underlying
your sales
         projections.
5.       Please provide us with your analysis of how aggregation of your
operating segments is
         consistent with the objective and basic principles of ASC 280. Refer
to ASC 280-10-50-
         11.
       Please contact Cara Lubit at 202-551-5909 or Marc Thomas at 202-551-3452
if you have
questions regarding comments on the financial statements and related matters.



FirstName LastNameJason Dubinsky                             Sincerely,
Comapany NameMorningstar, Inc.
                                                             Division of
Corporation Finance
November 17, 2023 Page 2                                     Office of Finance
FirstName LastName