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FOIA Confidential Treatment Request by

Morningstar, Inc. Pursuant to Rule 83
(17 C.F.R. 200.83)

May 31, 2023

Via EDGAR

    Cara Lubitz

    Marc Thomas

    Office of Finance

    Division of Corporation Finance

    U.S. Securities & Exchange Commission

    100 F Street, NE

    Washington, D.C. 20549

 Re: Morningstar, Inc.

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

                                            Filed February 24, 2023

                                            File No. 000-51280

Dear Ladies and Gentlemen:

On behalf of Morningstar, Inc., an Illinois
corporation (“Morningstar” or the “Company”), we are writing in response to the comments contained in the comment
letter dated April 24, 2023 (the “Comment Letter”) of the staff (the “Staff”) of the Securities and Exchange
Commission (“the Commission”) with respect to the Company’s Annual Report on Form 10-K for the year ended December 31,
2022. For the convenience of the Staff’s review, we have set forth the comments contained in the Comment Letter along with the
response of the Company.

Due to the commercially sensitive nature of certain
information contained in this response and the exhibits hereto, this letter is also a request for confidential treatment of the bracketed
portion of this response and exhibits (designated by “[***]”) pursuant the Commission’s confidential treatment procedure
under Rule 83 (17 C.F.R. § 200.83).

Notes to Consolidated Financial Statements

6. Segment and Geographical Area Information,
page 93

FOIA Confidential Treatment Request by

Morningstar, Inc. Pursuant to Rule 83
(17 C.F.R. 200.83)

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 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.

    2

FOIA Confidential Treatment Request by

Morningstar, Inc. Pursuant to Rule 83
(17 C.F.R. 200.83)

Response:

Summary

In determining and continuing to support its conclusion
on its reportable segments, the Company referred to the guidance provided in FASB ASC 280, Segment Reporting (ASC 280), which
employs a management approach in determining a company’s operating and reportable segments and, in turn, the presentation of disaggregated
information by segment. The Company acknowledges that additional financial information, including relative and directional margins by
revenue type and product area, is available and was made available due to requests from its shareholders given the Company’s interest
in providing transparency when possible, and was provided with appropriate considerations and caveats as to the nature of its preparation.
The Company concluded that its business activities and products covered by the Company’s reporting of revenue by type or product
area may meet the definitions of a component and business activity. However, the Company does not believe this information constitutes
discrete financial information in the context of ASC 280. The Company further discusses its rationale for this conclusion later in this
letter. In addition, none of this financial information at the revenue by type or product area level is used by its chief operating decision
maker (CODM), Kunal Kapoor, Chief Executive Officer (CEO), in making decisions about resource allocation or strategic initiatives. Therefore,
the Company concludes that a single reportable segment continues to be appropriate. The Company’s analysis is provided below.

Segment Identification Analysis

Identify the CODM1

Following
the steps outlined in ASC 280, the Company continues to conclude that its CODM is Kunal Kapoor, who is the Company’s CEO. The CODM
focuses on total Company strategy and delivery of its suite of products to drive long-term revenue and operating income growth. The
CODM is the only member of the management team with the authority to make or approve significant operating or strategic decisions (subject
to oversight by the Company’s Board of Directors) related to resource allocation, capital allocation, operating expense spending
levels, and merger and acquisition activity.

1 This section is responsive to the
request in the Comment Letter to “Describe the role of your CODM” in the second bulleted item of Question 1.

    3

FOIA Confidential Treatment Request by

Morningstar, Inc. Pursuant to Rule 83
(17 C.F.R. 200.83)

Identify Components and Operating Segments
of the Company’s Operations

The FASB Master Glossary defines a component as
follows:

“A component of an entity comprises operations
and cash flows that can be clearly distinguished, operationally and for financial reporting purposes, from the rest of the entity. A
component of an entity may be a reportable segment or an operating segment, a reporting unit, a subsidiary or an asset group.”

In determining its operating segments(s), the
Company considered the definition of operating segments in ASC 280-10-50-1 as follows:

“An operating segment is component of
a public entity that has all of the following characteristics:

 a. It engages in business activities
                                            from which it may earn revenues and incur expenses (including revenues and expenses relating
                                            to transactions with other components of the same public entity).

 b. Its operating results are regularly
                                            reviewed by the public entity’s chief operating decision maker to make decisions
                                            about resources to be allocated to the segment and assess its performance.

 c. Its discrete financial information
                                            is available.”

The FASB Master Glossary defines a component as
follows:

“A component of an entity comprises operations
and cash flows that can be clearly distinguished, operationally and for financial reporting purposes, from the rest of the entity. A
component of an entity may be a reportable segment or an operating segment, a reporting unit, a subsidiary or an asset group.”

Management’s assessment of each criterion
in relation to its Company-specific circumstances follows.

 A. Business Activities

Management views the Company as a portfolio of
product areas that utilize a core set of data, research, and other shared or central functions. To achieve its overall strategic and
financial objectives and best serve its clients, the Company’s operating model is organized by product or product groupings (product
areas) and corporate or central functions (central functions). Within this structure, thee product areas engage in business activities
that generate revenues and incur certain expenses, while the central functions primarily generate expenses, some of which are direct
expenses of the product areas and others are allocated.

    4

FOIA Confidential Treatment Request by

Morningstar, Inc. Pursuant to Rule 83
(17 C.F.R. 200.83)

In
its reports on Forms 8-K, 10-Q, and 10-K filed or furnished, as applicable, with the Securities and Exchange Commission (SEC), the Company
reports revenue in two ways: by type and for its largest product areas. Revenue by type consists of License-Based, Asset-Based, and Transaction-Based
categories and is used to provide better clarity to investors on business activities and how revenue is recognized under the different
revenue recognition models in accordance with the applicable accounting guidance. Additionally, the Company reports revenue for
certain key product areas (PitchBook, Morningstar Data, DBRS Morningstar, Morningstar Direct, Investment Management, Morningstar
Sustainalytics, Workplace Solutions, and Morningstar Advisor Workstation) to provide additional information to help investors track revenue
trends and understand contributors to total Company revenue performance. In the product development, maintenance, and delivery of its
products, the Company incurs various direct and indirect expenses, including, but not limited to, compensation, data purchases, and information
technology infrastructure. As a result, the Company concludes that its product areas and groupings of revenue by type meet criterion
a., “It engages in business activities from which it may earn revenues and incur expenses (including revenues and expenses
relating to transactions with other components of the same public entity)”. The central functions do not meet this criterion
since they primarily generate expenses.

 B. Operating Results Regularly Reviewed
                                            by CODM

The
Company has several leaders who report to the CODM that are accountable for product areas or central functions based on its management
structure. For purposes of individual performance management of these leader and to track the status and achievement of Company-wide
goals and cross-Company initiatives that require collaboration across product areas and central functions, the CODM periodically receives
financial information on a product or product area level; however, the CODM does not utilize this information for making decisions regarding
resource allocation.

Organization Structure2

There are 16 members of the Executive Leadership
team at the Company and the CODM has 13 direct reports. Leaders of central functions are responsible for managing areas such as research,
information technology systems and infrastructure, sales, customer service, marketing, design, legal, finance, facilities and real estate,
and human resources, which are leveraged and shared across the Company. Product area leaders are responsible for managing specific products
or product groupings. Some leaders have responsibilities for both central functions and product areas. Product area leaders’ responsibilities
are reorganized from time to time to reflect strategic priorities, address market trends, provide professional development opportunities
for the Executive Leadership team, or for other reasons. Currently, the product area leaders are organized into the following seven areas
of responsibility:

 · DBRS
                                            Morningstar

 · Enterprise

2 This section is responsive to the request in the Comment
Letter to “Provide us with details on your current management structure and how your Company is organized…” in the
first bulleted item of Question 1.

    5

FOIA Confidential Treatment Request by

Morningstar, Inc. Pursuant to Rule 83
(17 C.F.R. 200.83)

 · Morningstar
                                            Indexes

 · Morningstar
                                            Sustainalytics

 · Morningstar
                                            Wealth

 · PitchBook

 · Workplace
                                            Solutions

The primary rationale for the current product
groupings is to:

 · Align
                                            products and services under common leadership to better serve customers and end markets;

 · Maximize
                                            the value of the core data and research assets;

 · Move
                                            certain operations into the direct control of product area leadership to facilitate increased
                                            accountability; and

 · Provide
                                            an ability to structure and track more specific internal metrics to monitor individual performance.

By comparison, for purposes of its key product
area revenue disclosures in its most recent Forms 8-K, 10-Q, and 10-K, the Company defines its key product areas as follows:

 · PitchBook

 · Morningstar
Data3

 · DBRS
                                            Morningstar

 · Morningstar
                                            Direct3

 · Investment
Management4

 · Morningstar
                                            Sustainalytics

 · Workplace
                                            Solutions

 · Morningstar
                                            Advisor Workstation3

The primary rationale for this key product area
disclosure is to provide shareholders’ information on the Company’s largest and flagship products that customers recognize
as part of the Morningstar brand and suite of offerings. In aggregate, these product areas comprised 80.4% of total revenue as of December 31,
2022.

3 Morningstar Data, Morningstar Direct, and Advisor Workstation
are part of the Enterprise product area.

4 Investment Management is part of the Morningstar Wealth
product area.

    6

FOIA Confidential Treatment Request by

Morningstar, Inc. Pursuant to Rule 83
(17 C.F.R. 200.83)

In addition to the CEO, the Executive Leadership
team consists of the following individuals:5

    Name
    Title
    Reports
    to

CODM
    Responsibility

    [***]*
    Chief
    Marketing Officer

    Central
    Function

    [***]
    Chief
    of Staff
    X
    Central
    Function

    [***]**
    President,
    Morningstar Indexes

    Product
    Area

    [***]
    Chief