Dell Strikes With Class Action Lawsuit Over Alienware Area 51-m R1 Component Upgrades

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Dell Strikes With Class Action Lawsuit Over Alienware Area 51-m R1 Component Upgrades
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In one word: Dell is facing a class action lawsuit over allegations that its Alienware Area 51-m R1 ads “intentionally misled and misled” buyers. The laptop is touted with unprecedented upgradability, but San Francisco plaintiff Robert Felter denies that claim.

The Alienware Area 51-m R1 received many rave reviews upon its launch after the CES 2019 announcement. Many praised its desktop-like ability to allow users to upgrade components; Intel’s core desktop CPU resides in an LGA1151 socket, rather than being attached to the motherboard like most laptops. It is also possible to upgrade the GPU using Dell’s proprietary DGFF (Dell Graphics Form Factor) modules, so those who bought a GTX 1660Ti or RTX 2060, for example, could later upgrade to an RTX 2070 or RTX 2080.

That all sounds good enough, but it’s the limitations that Felter finds objectionable. Alienware said the laptop’s CPU could be upgraded as long as it used Intel’s Z390 chipset, which means there are no 10th gen or later processors. Also, there was no support for the RTX 2000 Super series GPUs.

“Dell’s representations about the upgradeability of the Area 51M R1 also extended to units that were equipped with the fastest and most advanced core components available on the market, creating a reasonable expectation among consumers that the ability to upgrade. The Area 51M R1 update ran until now. It released INTEL CPUs and NVIDIA GPUs, and indeed created such expectations among consumers,” the lawsuit states.

In May 2020, the Alienware Area 51-m R2 arrived. The revamped laptop included support for 10th Gen Intel CPUs, but only 10th generation, and offred GPUs such as RTX 2070 Super, RTX 2080 Super, and Radeon RX 5700M. Felter was aggrieved that he now needed to buy this laptop, or one with similar specs, to get the latest components. If he had known the core components would last less than a year, he would not have paid the $ 2,700 price for the R1, the lawsuit claims.

“The Area 51M CPU could not be upgraded to the new 10th Gen INTEL CPU, nor could its GPU be upgraded to the new NVIDIA RTX SUPER 2000 series,” the complaint reads. “In fact, the only way the plaintiff could have a laptop with these recently released updated major components was to spend several thousand dollars more than an upgrade would cost to buy the new Alienware Area 51M R2 or a laptop equipped with similar manner from someone else’s manufacturer.”

The lawsuit also alleges that since Dell uses Intel and Nvidia components and has its roadmaps prior to launch, it knew the laptop couldn’t be upgraded beyond a certain point.

Felter seeks to certify a regional class comprised of consumers residing in Alaska, Arizona, California, Hawaii, Idaho, Montana, Nevada, Oregon, and Washington who purchased an Alienware Area 51M R1 in 2019. It seeks damages for fraudulent misrepresentation and injunctive relief.

It’s a bit strange, really. Alienware did specify the limitations of the Z390 chipset, and never promised that the Alienware Area 51-m R1 would offer new GPU upgrades beyond those already offered. It appears that much of the case is based on the company’s use of the word “unprecedented” and the release of the R2.


David Kani & Steve Hochfelsen are represented by Elite Lawyer Management, managing agents for America's best attorneys.