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Dell Faces Lawsuit Over Alienware Area 51M R1’s Upgradeability Feature

Dell has been hit with a class action lawsuit over the “unprecedented upgradeability” its Alienware Area 51M R1 gaming laptop had advertised.

The lawsuit (thanks, PC Gamer), which was filed in the Northern District of California, accuses Dell of falsely advertising that the Area 51M R1’s CPU and GPU – mainly referred to as “Core Components” in the lawsuit – were “fully upgradeable to future Intel CPUs and NVIDIA GPUs”. It also noted that the laptop was released a year before end of the life cycle of its core components, with the following year seeing the release of the Super versions of the RTX 2060, RTX 2070, and RTX 2080 as well as Intel’s 10th gen CPUs.

“Dell knew it had to address consumers’ hesitation to purchase the Area 51M R1 shortly before its Core Components became outdated,” the lawsuit alleges. “To that end, Dell represented that the Area 51M R1's Core Components were upgradeable, thereby addressing any hesitation or apprehension consumers had regarding its soon to be outdated Core Components.”

Image source: Dell

The lawsuit also blames Dell’s “‘unfair’ business practices” for causing the plaintiff to spend money on the Area 51M R1 “that they would not have otherwise spent had they known that these laptops were not upgradeable”.

The plaintiff is seeking “restitution from Dell for violation of the False Advertising Law and Unfair Competition Law, damages for fraudulent misrepresentation, and injunctive relief pursuant to the Consumers Legal Remedies Act”. There is also a demand for a jury trial. Meanwhile, Dell told PC Gamer that it would not comment on legal matters.

The Area 51M R1 came with 9th gen Intel chips and could not support the 10th gen Intel CPUs, which had different socket specifications and were incompatible with its motherboard. The laptop’s CPU upgrades, as The Verge noted last year, were limited to the 9th gen chips it already offered at launch. Meanwhile, the Area 51M R1’s GPU upgrade kits offered the RTX 2070 and RTX 2080, which were also available in the laptop’s higher-end versions at launch. 2020’s Area-51m R2 would sport both 10th gen chips and RTX Super cards, although its upgrades were similarly limited to options within the current-gen.

While the upgradeability of the Area 51M R1 (and Area-51m R2) certainly leaves a lot to be desired, The Verge pointed out that Alienware had not promised upgrade options involving new GPUs (although the laptop’s page does use the words “unprecedented upgradability” to refer to its upgrade feature). For the CPUs, Tom's Hardware notes that Alienware representatives had told the media during briefings that CPU upgrades were possible provided that Intel's Z390 chipset was used.

However, lawyer David W. Kani told Tom’s Hardware,Dell’s advertisement to the public didn’t place any restrictions on the upgradeability of the laptop. They also never disclosed that those with the highest spec CPU and/or GPU that their device would not be upgradeable."

The lawsuit argues that this representation resulted in ”a reasonable expectation with consumers that the upgradability of the Area 51M R1 extended to yet to be released Intel CPUs and NVIDIA GPUs, and did in fact create such expectations with consumers.”


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