A California man has filed for a class action lawsuit against PC manufacturer Dell, claiming that the company "intentionally misled and deceived" buyers of its Alienware Area 51-m R1 gaming laptop, which was advertised to be more upgradeable than other gaming notebooks.
The plaintiff, Robert Felter, who is based in San Francisco, alleges that Dell misleads customers to believe that the laptop would be upgradeable, possibly into future generations of components. The case, Felter v. Dell Technologies, Inc. (3:21-cv-04187) has been filed with the United States District Court in the Northern District of California.
The Alienware Area 51-m was announced at CES 2019 and launched soon after. (The complaint claims the announcement was made in the summer of 2019, which is incorrect.). Among the Area 51-m's biggest touted innovations were a user-replaceable CPU and GPU.
At media briefings, Alienware representatives told the press that the CPU could be upgraded as long as it used Intel's Z390 chipset. The laptop used Intel's 9th Gen Core desktop processors, up to the Intel Core i9-9900K. Dell developed separate proprietary Dell Graphics Form Factor (DGFF) modules for the Nvidia graphics.
The lawsuit, however, claims that consumers were told that "core components" (meaning the CPU and GPU) could be replaced beyond the current generation of hardware.
"Dell’s advertisement to the public didn’t place any restrictions on the upgradeability of the laptop," lawyer David W. Kani said in an email to Tom's Hardware. "They also never disclosed that those with the highest spec CPU and/or GPU that their device would not be upgradeable."
Representatives for Dell said the company's policy is not to comment on pending litigation.
The complaint reads that "Dell’s representations of the upgradability of the Area 51M R1 also extended to units that were equipped with the fastest, most advanced Core Components available to the market, thus creating 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." Several times, the complaint refers to Dell's claims of "unprecedented upgradeability."
Those words indeed live on Dell's web page for the Alienware Area-51M R1.
"Gamers have made it clear that they’ve noticed a lack of CPU and GPU upgradability in gaming laptops," it reads. "The Area-51m was engineered with this in mind, finally allowing gamers to harness power comparable to even the highest-performance desktop... CPU upgrades can be done using standard desktop-class processors, while GPU upgrades can be done with GPU upgrade kits available on Dell.com or with the Alienware Graphics Amplifier."
The case is an interesting one in the enthusiast space. At its essence, this boils down to a motherboard with Intel's Z390 chipset as well as the proprietary graphics cards. Motherboards are upgraded at a regular cadence to work with the latest processors, though occasionally new processors will work on older boards. This could potentially set a sort of precedent about how far out a motherboard needs to support a CPU. In desktops, GPUs typically work for years, as long as it's not using an outdated standard. But Dell's graphics were in a proprietary form factor.
Felter is seeking damages, relief and attorneys fees for himself and those in Alaska, Arizona, California, Hawaii, Idaho, Montana, Nevada, Oregon, and Washington state who purchased the laptop on their own since its release in 2019. He is represented by attorneys Brian H. Mahany of Mahany Law and Steven I. Hochfelsen and David W. Kani of Hochfelsen & Kani, LLP. He is asking the court for a jury trial.
Update - June 4, 9:30 a.m. ET - Updated with response from Dell.
