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                             May 27, 2020

       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, 2019
                                                            Filed March 2, 2020
                                                            File No. 000-51280

       Dear Mr. Dubinsky:

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

              Please respond to the 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 the comments, we may have additional comments.

       Form 10-K for the Fiscal Year Ended December 31, 2019

       Item 8. Financial Statements and Supplementary Data
       Notes to Consolidated Financial Statements
       6. Segment and Geographical Area Information, page 86

   1.                                                   We note from your
disclosure on page 11 that your current business model consists
                                                        of selling products and
services within following three major categories: Licensed-based,
                                                        Asset-based, and
Transaction-based (each of which represent more than 10% of total
                                                        revenues). We also note
from Question 3 in the 8-K dated March 13, 2020 that you
                                                        discuss operating
margins for these categories. Provide us with your analysis supporting
                                                        your conclusion that a
single reportable segment is appropriate pursuant to the
                                                        requirements of ASC
280. Please address the following in your response:
                                                          We understand that
certain of your major products and services have separate chief
                                                             executive
officers, heads, and presidents, etc. Tell us how you define your Chief
                                                             Operating Decision
Maker ("CODM"), for example, an individual or group.
 Jason Dubinsky
Morningstar, Inc.
May 27, 2020
Page 2
              Explain to us the key measures the CODM uses in assessment of
performance and
              allocation of resources. Tell us if you provide detailed
operating margin information,
              other than at the consolidated level, (e.g., at the major
category level, as referenced
              above or for your major products and services) to the CODM.

       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 Michael Henderson, Staff Accountant at 202-551-3364 or
Lory Empie,
Staff Accountant at 202-551-3714 with any questions.



FirstName LastNameJason Dubinsky                               Sincerely,
Comapany NameMorningstar, Inc.
                                                               Division of
Corporation Finance
May 27, 2020 Page 2                                            Office of
Finance
FirstName LastName