In Tiny 1, Ltd. v. Samfet Marble, No. 14948, 2022 WL 24305, at *2 (1st Dep't. Jan. 4, 2022), the Appellate Division, First Department held that "unique circumstances" of an arms-length transaction gave rise to fiduciary duties. This holding diverges from the well-established principle that arms-length transactions generally do not create fiduciary obligations and arguably raises the bar for fiduciaries by expanding the scope of liability stemming from transactions that would ordinarily be shielded from scrutiny. Tiny I follows another similar decision in Pennsylvania, suggesting a potential trend towards expansion of fiduciary duty relationships in traditional arms-length transactions and an issue to keep an eye on.