Dell hit with class-action lawsuit over Alienware Area 51-m R1 component upgrades

midian182

Posts: 7,175   +65
Staff member
In a nutshell: Dell is facing a class-action lawsuit over allegations that ads for its Alienware Area 51-m R1 "intentionally misled and deceived" buyers. The laptop is promoted as featuring unprecedented upgradeability, but San Francisco-based plaintiff Robert Felter disputes that claim.

The Alienware Area 51-m R1 received plenty of glowing reviews following its release after the CES 2019 announcement. Many praised its desktop-like ability that allows users to upgrade the components; the Intel core desktop CPU resides in an LGA1151 socket, rather than being soldiered to the motherboard like most laptops. It's 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 pretty good, but it's the limitations that Felter finds objectionable. Alienware did say that the laptop's CPU could be upgraded provided it used Intel's Z390 chipset, meaning no 10th gen processors or later. Additionally, there was no support for the RTX 2000 Super series GPUs.

"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," states the suit.

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

"The Area 51M's CPU was not upgradeable to the new INTEL 10th generation CPU, nor was its GPU upgradeable to the new NVIDIA RTX SUPER 2000 series," the complaint reads. "In fact, the only way Plaintiff could own a laptop with these newly released upgraded Core Components was to spend several thousand dollars more than what an upgrade would cost to purchase the then-newly released Alienware Area 51M R2 or a similarly equipped laptop from another manufacturer."

The suit also alleges that as Dell uses Intel and Nvidia components and has its roadmaps before they're released, it knew the laptop could not be upgraded beyond a certain point.

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

It's a bit of a strange one, really. Alienware did specify the Z390 chipset limitations, and it never promised the Alienware Area 51-m R1 would offer new GPU upgrades beyond those already on offer. It appears much of the case rests on the company's use of the word "unprecedented" and the release of the R2.

h/t: Tom's Hardware

Permalink to story.

 

Dimitriid

Posts: 1,156   +2,204
Although I think Dell will get off without much problem with a bit of arguing semantics about their claims, just the fact that it made the news it's already kind of a positive development: more people should know that every time a laptop is sold to you as "upgradeable" it's basically a scam.

At the very least, you should be seeking reviews of any laptop instead of trusting manufacturers: soldering unnecessary stuff like SSDs and RAM is certainly bad but if you just trust someone like Dell they'll either won't tell you, use a proprietary format or pull off a scam like this on the other end of the spectrum (replace-able CPU and GPU! Except we don't really have any real upgrade options beyond what's available at launch)
 

Ravey

Posts: 322   +138
You dont need a laptop to be 100% upgradeable anyway. I'm fairly certain I'll be able to switch out the GTX1080 in my MSI Titan Pro when it's time too.. Once that burns out, it will be time for a new laptop anyway.. would be more affordable to buy new than upgrade at that point.

The only thing I'll need to decide is whether to attempt upgrading the card myself or have a shop do it :)
 

QuantumPhysics

Posts: 5,305   +6,028
I love my Alienware R4 Laptop, but let’s be serious: the whole idea of an upgradable gaming laptop was ridiculous.

#1 There was no way you could upgrade beyond the 2000 series.

#2. There was no way you could upgrade beyond the generation/socket of CPU it’s limited to.

#3. Even if you could upgrade the CPU and GPU you’d still be stuck with an old motherboard and old RAM.

The way I see it: it makes more sense to lease gaming laptops - or to buy them every four or five years while selling the older one on the Internet.

There are some people who use their laptop as a desktop replacement and they tend to buy the most powerful laptop they can get.

Personally: when I upgrade from my R4 1080 GTX, I will get a 3080 RTX or I’ll just wait for the 4000 series.

If I had it to do all over again I might have just spent more money and bought into the 2000 (2070) series rather than by the 1080 model.

I was never convinced that I was going to see any true Ray Tracing using a laptop monitor but in retrospect I should’ve just upgraded as much as possible at the point of sale.

Ultimately: this is the reason why gaming laptops are a quickly depreciating asset and not a good investment unless you truly intend on using that laptop for more than 90% of your PC use.

The CPU in my laptop will have more useability than the GPU does.
 

Theinsanegamer

Posts: 2,727   +4,262
I love my Alienware R4 Laptop, but let’s be serious: the whole idea of an upgradable gaming laptop was ridiculous.

#1 There was no way you could upgrade beyond the 2000 series.

#2. There was no way you could upgrade beyond the generation/socket of CPU it’s limited to.

#3. Even if you could upgrade the CPU and GPU you’d still be stuck with an old motherboard and old RAM.

The way I see it: it makes more sense to lease gaming laptops - or to buy them every four or five years while selling the older one on the Internet.

There are some people who use their laptop as a desktop replacement and they tend to buy the most powerful laptop they can get.

Personally: when I upgrade from my R4 1080 GTX, I will get a 3080 RTX or I’ll just wait for the 4000 series.

If I had it to do all over again I might have just spent more money and bought into the 2000 (2070) series rather than by the 1080 model.

I was never convinced that I was going to see any true Ray Tracing using a laptop monitor but in retrospect I should’ve just upgraded as much as possible at the point of sale.

Ultimately: this is the reason why gaming laptops are a quickly depreciating asset and not a good investment unless you truly intend on using that laptop for more than 90% of your PC use.

The CPU in my laptop will have more useability than the GPU does.
#2 is sensible, but #1 and #3 are nonsense.

#1 there is no reason you could not have gone beyond the 2000 series. It's a GPU communicationg over a PCIe bus. GPUs from the 8000 series to the 900 series all used MXM, all you needed was support in the bios for switching cards. Not being able to go to a new series of GPUs is bullshit.

#3 oh noes, an old motherboard? Who cares? It works fine, CPUs dont age nearly as bad as GPUs do. 9th gen CPUs are more then capable of playing the latest games. Same with RAM. Oh no, its old RAM! But newer motherboards still use DDR4. Simply allow XMP, which an enthusiast gaming laptop should already allow, and this is again a non problem.

I hope he wins, dell is scum of the earth. They cheap out in the worst ways and try to slip subscription services they refuse to cancel into people's bills. They lie about configurations and sell total garbage machines that are designed to last just past their warranty before outright failing for WAY too much money.
 

QuantumPhysics

Posts: 5,305   +6,028
#2 is sensible, but #1 and #3 are nonsense.

#1 there is no reason you could not have gone beyond the 2000 series. It's a GPU communicationg over a PCIe bus. GPUs from the 8000 series to the 900 series all used MXM, all you needed was support in the bios for switching cards. Not being able to go to a new series of GPUs is bullshit.

#3 oh noes, an old motherboard? Who cares? It works fine, CPUs dont age nearly as bad as GPUs do. 9th gen CPUs are more then capable of playing the latest games. Same with RAM. Oh no, its old RAM! But newer motherboards still use DDR4. Simply allow XMP, which an enthusiast gaming laptop should already allow, and this is again a non problem.

I hope he wins, dell is scum of the earth. They cheap out in the worst ways and try to slip subscription services they refuse to cancel into people's bills. They lie about configurations and sell total garbage machines that are designed to last just past their warranty before outright failing for WAY too much money.


So you think an old motherboard has the capability to take full advantage of future hardware abilities - without the manufacturers knowing what the future abilities will be?

Before you reply, consider whether or not you should.
 

brucek

Posts: 902   +1,307
Certainly we've had many generations of desktop motherboards that could each accommodate multiple generations of GPUs.

The fine print is in there that the GPU upgrade has to be a kit from Dell, but given most of the marketing hype is trying to paint the picture of a laptop with the same upgradeability as a desktop, I'm not surprised some people ended up disappointed.
 

ikesmasher

Posts: 3,131   +1,537
So you think an old motherboard has the capability to take full advantage of future hardware abilities - without the manufacturers knowing what the future abilities will be?

Before you reply, consider whether or not you should.
Yes thats typically how PCIe works believe it or not.
Your original argument hinges on a motherboard and ram being a massive bottleneck for a next gen processor which is absolute nonsense. Even on AMD, which is much more ram sensitive, the impact of using an "old" motherboard (There are 3-4 year old motherboards that can support 5xxx) and slow ram can be measured in single digit percentages versus top end.

Dell made the modularity of this laptop its primary selling point, and then decided to not provide any worthwhile compatible modular parts. Even if they legally get away with it its ethically scummy and not worth defending in any capacity.

Dell is the king of designing amazing products and ruining them with awful QC, support, software, and logistics. Fool us once...
 

TheBigT42

Posts: 578   +545
"Alienware did say that the laptop's CPU could be upgraded provided it used Intel's Z390 chipset"

That's for all Mother Boards. This is just a ambulance chaser trying to get some $$$
 

terzaerian

Posts: 990   +1,436
We used to be able to upgrade the CPU in most laptops, and thr GPU in gaming ones what happened.
Apple, and their pursuit of thinner and lighter (conveniently to the detriment of replaceable parts and repairability). The rest of the sector decided to ape rather than innovate.
 

duckofdeath

Posts: 448   +586
So you think an old motherboard has the capability to take full advantage of future hardware abilities - without the manufacturers knowing what the future abilities will be?

Before you reply, consider whether or not you should.
The argument you made is nonsense. No computer, prebuilt or custom built is "future proof", as power, socket, or any other critical component "standard" can change over night.
It's still infinitely better than everything being soldered on. A simple storage upgrade, a few years down the road, always delivers a good performance boost. The same goes for memory upgrades.
 

Xex360

Posts: 160   +233
Apple, and their pursuit of thinner and lighter (conveniently to the detriment of replaceable parts and repairability). The rest of the sector decided to ape rather than innovate.
The annoying thing is they don't copy what Apple gets right, like the screen most are stuck in stupid Full HD, and then the trackpad.
 

hwertz

Posts: 73   +34
I would not expect much for CPU upgrades -- pretty much after socket 7 (waaaay back), it's pretty normal to have 'em switch up sockets and chipset compatibility pretty often.

But on non-integrated mobile GPUs (I.e. not Intel GPU or much more recently not the ones built into Ryzen), people have for decades been able to yank the old card and put a new one in; even if unsupported by the vendor, it would typically work as long as you put one in that didn't blow the heat and power budget. So it'd be completely reasonable to expect to pop in the 2070 Super etc. Seriously, good luck on your lawsuit!
 

Bobbydpue

Posts: 226   +147
You dont need a laptop to be 100% upgradeable anyway. I'm fairly certain I'll be able to switch out the GTX1080 in my MSI Titan Pro when it's time too.. Once that burns out, it will be time for a new laptop anyway.. would be more affordable to buy new than upgrade at that point.

The only thing I'll need to decide is whether to attempt upgrading the card myself or have a shop do it :)
No one "needs" a gaming laptop anyway, but that's not what this is about. Dell made it appear this laptop would be upgradable in the future, but if a person bought the top spec one there is nothing to upgrade making the whole upgradable feature useless making the extra cost unnecessary.
 

Xex360

Posts: 160   +233
I don't remember any such laptop, could you list the laptops and the GPUs that were made available?
Back in the Sandy Bridge era, mobile CPUs weren't soldered and you could upgrade them to same extent depending on your motherboard.