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FOIA Confidential Treatment Request by Morningstar, Inc. Pursuant
to Rule 83 (17 C.F.R. 200.83). This letter requests confidential treatment of the bracketed portions of this letter (designated
by “[***]").

February 21, 2024

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

                                            Response dated December 15, 2023

                                            File No. 000-51280

Ladies and Gentlemen:

On behalf of Morningstar, Inc., an Illinois
corporation (the “Company” or “Morningstar”), we are writing in response to the comments contained in the comment
letter dated February 7, 2024 (the “Comment Letter”) of the staff (the “Staff”) of the Securities and Exchange
Commission with respect to the Company’s Annual Report on Form 10-K for the year ended December 31, 2022 (the “Form 10-K”).
For the convenience of the Staff’s review, we have set forth the comment 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, this letter is also a request for confidential treatment of the bracketed portions of this response
(designated by “[***]") pursuant to the Commission’s confidential treatment procedure under Rule 83.

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.

FOIA Confidential Treatment Request by Morningstar, Inc.
Pursuant to Rule 83 (17 C.F.R. 200.83). This letter requests confidential treatment of the bracketed portions of this letter (designated
by “[***]").

Response:

In response to your objection, and as described in more detail below,
we have revised our segment disclosure and concluded upon the following five reportable segments, which are also individual operating
segments as shared in our comment letter response dated November 9, 2023:

 ● Morningstar Data &
                                            Analytics (Enterprise)

 ● PitchBook

 ● Morningstar Wealth (Wealth)

 ● Morningstar Credit (Morningstar DBRS)

 ● Morningstar Retirement
                                            (Retirement)

Our remaining operating segments, Morningstar Indexes (Indexes) and
Morningstar Sustainalytics (Sustainalytics), will not be presented as reportable segments as they do not meet the quantitative thresholds
outlined in ASC 280-50-10-12, nor will they be aggregated into a reportable segment per ASC 280-50-10-13, and will instead be reported
as “Corporate and All Other” in accordance with ASC 280-10-50-15.

Please see Appendix A for our revised segment footnote disclosure
that will be included within the Notes of our Audited Consolidated Financial Statements included in the Company’s Annual Report
on Form 10-K for the period ended December 31, 2023, that we plan to file with the Securities and Exchange Commission on February 29,
2024.

ASC 280 Analysis

In order to address your concerns, we have reassessed the aggregation
criteria in ASC 280-10-50-11 and concluded that the Company will not be aggregating any of our seven operating segments.

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FOIA Confidential Treatment Request by Morningstar, Inc.
Pursuant to Rule 83 (17 C.F.R. 200.83). This letter requests confidential treatment of the bracketed portions of this letter (designated
by “[***]").

We applied the 10% quantitative thresholds outlined in ASC 280-10-50-12
(the “10% tests”) to our seven operating segments. Based on final 2021, 2022, and 2023 revenue and profit/loss for our operating
segments, we determined that Enterprise, PitchBook, Wealth, Morningstar DBRS, and Retirement should each be a separate reportable
segment as their revenue and/or profit/loss exceeded 10% in at least one of the periods presented1.

Once we applied the 10% tests under ASC 280-10-50-12 and determined
which operating segments are required to be shown as reportable segments, we applied the guidance under ASC 280-10-50-14, which further
requires that reportable segment external revenues aggregate to at least 75% of an entity’s consolidated revenue (the “75%
of Revenue Test”). The five reportable segments determined under the 10% tests represent over 91% of Morningstar’s consolidated
revenue in each of 2021, 2022, and 2023, thus satisfying the 75% of Revenue Test. These reportable segments also represent 92% of reported
profit/loss in each of the years presented.

Therefore, after satisfying the 75% of Revenue Test, our two
remaining operating segments, Indexes and Sustainalytics, which are both below 10% of Morningstar’s consolidated revenue
and profit/loss will be presented as “Corporate and All Other”. We considered the guidance in ASC 280-10-50-13, but
concluded these operating segments should not be aggregated and combined as a reportable segment, given they do not meet the
criteria established in ASC 280-10-50-13 and ASC 280-10-50-11. By applying ASC 280-10-50-15, operating segments that are not
reportable are required to be combined and disclosed in an “all other” category. Accordingly, we included Indexes and
Sustainalytics in “Corporate and All Other” and not as a reportable segment. Rather, “Corporate and All
Other” provides a reconciliation between revenue from our reportable segments and consolidated revenue amounts. In addition to
Indexes and Sustainalytics revenue and profit/loss, the “Corporate and All Other” category includes unallocated corporate
expenses, such as finance, human resources, legal, and other management-related costs that are not considered when segment
performance is evaluated.

ASC 280 Objectives

The Company notes the general objectives of segment reporting outlined
in ASC 280-10-10-1, which are intended to assist financial statement users in better understanding an entity’s performance, its
prospects for future net cash flows, and to make more informed judgments about the entity as a whole. The Company believes that its updated
segment reporting outlined in this response letter is consistent with these objectives given the significant percentage of both revenues
and profit/loss included as reportable segments and separate disclosure of sources of revenue included in the “Corporate and All Other”
category consistent with the disclosure requirements of ASC 280-10-50-15.

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FOIA Confidential Treatment Request by Morningstar, Inc.
Pursuant to Rule 83 (17 C.F.R. 200.83). This letter requests confidential treatment of the bracketed portions of this letter (designated
by “[***]”).

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If you have any questions regarding the responses in this letter,
please call me at (312) 244-7581.

Respectfully submitted,

    /s/ Jason Dubinsky

Jason Dubinsky

Chief Financial Officer

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FOIA Confidential Treatment Request by Morningstar, Inc.
Pursuant to Rule 83 (17 C.F.R. 200.83). This letter requests confidential treatment of the bracketed portions of this letter (designated
by “[***]”).

Appendix A

[***]

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