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 | 5 min read | 08.21.26
FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know
On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement.
Client Alert | 4 min read | 08.07.26
Missouri AG Sues Kansas City Over Race- and Sex-Based Contracting Program
Blog Post | 08.07.26
Missouri AG Sues Kansas City Over Race- and Sex-Based Contracting Program
Blog Post | 08.03.26
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
Missouri AG Sues Kansas City Over Race- and Sex-Based Contracting Program
|08.07.26
Crowell & Moring's State AG Blog State AG News: Food Distributors, Pet Stores, Healthcare (July 2-8, 2026)
|07.10.26
Crowell & Moring's State AG Blog
When Sharing Becomes Collusion: Bipartisan AG Settlement Outlines Pricing Compliance
|07.09.26
Crowell & Moring's State AG Blog FTC Blog Updates (June 15-26, 2026)
|07.06.26
Crowell & Moring's Retail & Consumer Products Law Observer
FTC Blog Updates (April 27 - May 1, 2026)
|05.11.26
Crowell & Moring's Retail & Consumer Products Law Observer
State AG News: Pharmaceuticals, Infrastructure, Fraud Schemes (April 30-May 7, 2026)
|05.08.26
Crowell & Moring's State AG Blog
State AG News: Sports Betting, Credit Agencies, Grocery Stores (April 23-29, 2026)
|05.01.26
Crowell & Moring’s State AG Blog
FTC Blog Updates (April 20-24, 2026)
|04.28.26
Crowell & Moring's Retail & Consumer Products Law Observer
State AG News: Deceptive and Unfair Practices, Consumer Protection (April 2-8, 2026)
|04.23.26
Crowell & Moring’s State AG Blog
Tiffany's Insights
Client Alert | 5 min read | 08.21.26
FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know
On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement.
Client Alert | 4 min read | 08.07.26
Missouri AG Sues Kansas City Over Race- and Sex-Based Contracting Program
Blog Post | 08.07.26
Missouri AG Sues Kansas City Over Race- and Sex-Based Contracting Program
Blog Post | 08.03.26



