SEC Comment Letter 0000000000-24-001504 to Morningstar, Inc. (MORN) (CIK 0001289419) (MORN)
Morningstar, Inc. (MORN) (CIK 0001289419)
Date: Feb. 7, 2024 · CIK: 0001289419 · Accession: 0000000000-24-001504
AI Filing Summary & Sentiment
File numbers found in text: 000-51280
Letter
United States securities and exchange commission logo February 7, 2024 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 December 15, 2023 File No. 000-51280 Dear Jason Dubinsky: We have reviewed your December 15, 2023 response to our comment letter and have the following comment. 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 November 17, 2023 letter. Form 10-K for the Fiscal Year Ended December 31, 2022 6. Segment and Geographical Area Information, page 93 1.We have considered your November 9, 2023 and December 15, 2023 responses to our comments. Based upon the information provided, we do not believe the aggregation criteria in ASC 280-10-50-11 have been met and therefore object to your aggregation of the Enterprise, Pitchbook, and Morningstar Sustainalytics operating segments and the Morningstar Indexes, Wealth, and Retirement operating segments. Please revise your disclosures accordingly. 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 Comapany NameMorningstar, Inc. February 7, 2024 Page 2 FirstName LastName Jason Dubinsky Morningstar, Inc. February 7, 2024 Page 2 Sincerely, Division of Corporation Finance Office of Finance
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United States securities and exchange commission logo
February 7, 2024
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 December 15, 2023
File No. 000-51280
Dear Jason Dubinsky:
We have reviewed your December 15, 2023 response to our comment letter and have the
following comment.
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 November 17,
2023 letter.
Form 10-K for the Fiscal Year Ended December 31, 2022
6. Segment and Geographical Area Information, page 93
1.We have considered your November 9, 2023 and December 15, 2023 responses to our
comments. Based upon the information provided, we do not believe the aggregation
criteria in ASC 280-10-50-11 have been met and therefore object to your aggregation of
the Enterprise, Pitchbook, and Morningstar Sustainalytics operating segments and the
Morningstar Indexes, Wealth, and Retirement operating segments. Please revise your
disclosures accordingly.
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
Comapany NameMorningstar, Inc.
February 7, 2024 Page 2
FirstName LastName
Jason Dubinsky
Morningstar, Inc.
February 7, 2024
Page 2
Sincerely,
Division of Corporation Finance
Office of Finance