Tiffany Aguiar
Overview
Tiffany Aguiar is a counsel in the firm’s Antitrust and Competition and Advertising and Media groups and resides in the firm’s Orange County office.
Tiffany represents clients in matters related to investigations brought by the Federal Trade Commission and State Attorneys General. She is also a litigator with a practice that focuses on representing Fortune 500 companies across various industries in complex antitrust litigation.
Career & Education
- Cornell University, B.S., hotel administration, 2014
- University of California, Irvine School of Law, J.D., 2020
- California
Tiffany's Insights
Client Alert | 3 min read | 02.11.26
On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (FTC) Rule Concerning Subscriptions and Other Negative Option Plans, commonly known as the “Click-to-Cancel” rule. As detailed in a previous client alert, the rule was intended to regulate negative option plans[1]— such as subscriptions and automatic renewals — by imposing stringent requirements on businesses, including streamlined cancellation processes and enhanced disclosure obligations. The Eighth Circuit vacated the Click-to-Cancel rule because it found that the FTC had failed to comply with mandatory procedural requirements. As a result, the rule is no longer in effect, and businesses are not currently subject to its mandates.
Firm News | 9 min read | 01.09.26
Crowell & Moring Elects 15 New Partners, Promotes One to Senior Counsel and 26 to Counsel
Blog Post | 01.05.26
Insights
ESG in the Metaverse: An Opportunity to Rethink Sustainability
|05.24.23
Retail in the Metaverse and Beyond
Beauty and Justice: How Brands Targeting Women Of Color Can Assess Their Risks
|08.26.22
New York Law Journal
Raising the Bar: New York Expands Consumer Protection Law with FAIR Business Practices Act
|01.08.26
Crowell & Moring’s Retail & Consumer Products Law Observer
FTC Updates (December 15–19, 2025)
|01.05.26
Crowell & Moring’s Retail & Consumer Products Law Observer
FTC Updates November 17 – 21, 2025
|12.01.25
Crowell & Moring’s Retail & Consumer Products Law Observer
- |
11.25.25
Crowell & Moring’s State AG Blog
FTC Down to Two Commissioners After (Former) Commissioner Holyoak Leaves for U.S. Attorney Role
|11.20.25
Crowell & Moring’s Retail & Consumer Products Law Observer
- |
10.28.25
Crowell & Moring’s Retail & Consumer Products Law Observer
State AG News: Children’s Privacy, Consumer Fraud, Environmental Action (October 9-22, 2025)
|10.28.25
Crowell & Moring’s State AG Blog
FTC Updates September 2 – 26, 2025
|10.13.25
Crowell & Moring’s Retail & Consumer Products Law Observer
State AG News: Consumer Fraud, Misleading Ads, Tenant Rights August 28-September 3, 2025
|09.22.25
Crowell & Moring’s State AG Blog
Tiffany's Insights
Client Alert | 3 min read | 02.11.26
On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (FTC) Rule Concerning Subscriptions and Other Negative Option Plans, commonly known as the “Click-to-Cancel” rule. As detailed in a previous client alert, the rule was intended to regulate negative option plans[1]— such as subscriptions and automatic renewals — by imposing stringent requirements on businesses, including streamlined cancellation processes and enhanced disclosure obligations. The Eighth Circuit vacated the Click-to-Cancel rule because it found that the FTC had failed to comply with mandatory procedural requirements. As a result, the rule is no longer in effect, and businesses are not currently subject to its mandates.
Firm News | 9 min read | 01.09.26
Crowell & Moring Elects 15 New Partners, Promotes One to Senior Counsel and 26 to Counsel
Blog Post | 01.05.26




