Dell Falsely Claimed Area 51M R1 Gaming Laptop’s Core Components Were Fully Upgradeable, Class Action Alleges

A proposed class action alleges Dell Technologies has intentionally misled the public with regard to the apparent “upgradeability” of its flagship Alienware Area 51M R1 gaming laptop. 

The 20-page complaint, filed in California on June 2, charges that Dell has affirmatively and falsely misrepresented certain characteristics and qualities of the Area 51M R1 laptop that it knew did not exist to lure unsuspecting consumers into paying a higher price for the machine and gain a leg up in an intensely competitive marketplace.

According to the suit, Dell’s most prominent misrepresentation about the purportedly revolutionary laptop is the claim that its core hardware components—i.e., the central processing unit (CPU) and graphics processing unit (GPU)—are fully upgradeable to future Intel CPUs and NVIDIA GPUs. Per the case, Dell was aware that future upgradeability of a gaming laptop is of material interest to buyers, especially given that the core components of laptops are traditionally not upgradeable. The company touted this claim, the case says, to sell as many Area 51M R1s as possible before the computer’s core components reached the end of their life cycle, which was rapidly approaching:

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Dell knew it had to address consumers’ hesitation to purchase the Area 51M R1 shortly before its Core Components became outdated.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Components were upgradeable, thereby addressing any hesitation or apprehension consumers had regarding its soon to be outdated core components.”

In reality, the lawsuit stresses, the Area 51M R1’s core components are not upgradeable, and Dell has reportedly admitted as much.

Upgradeability is the “holy grail” of mobile computing, suit says

Unlike desktop computers, a laptop’s CPU and GPU, which are ultimately responsible for the machine’s gaming performance, are permanently affixed within the machine, making them impossible to remove and thus upgrade, the lawsuit says. As a result, consumers cannot swap their laptop’s core components for faster, more powerful next-generation CPUs and GPUs as the older components approach the end of their shelf life, the case states. Instead, consumers looking to upgrade their machine must buy an entirely new laptop to be able to play the latest, more technologically demanding games.

The lawsuit notes that the core components in different brands of gaming laptops are virtually identical, however, with all manufacturers offering the same Intel CPUs and NVIDIA GPUs. It’s for this reason, the case says, that manufacturers must go above and beyond to differentiate and market their products based on price, aesthetics or other unique features.

In Dell’s case, this “unique feature” was the “unprecedented upgradeability” of its machines - something the lawsuit calls the “elusive holy grail of mobile computing.”

Against the clock

Area 51M’s release came in summer 2019, about a year before the end of the life cycle of the laptop’s core components, the suit says. Per the case, NVIDIA was set to and did release its updated, more powerful GPUs (the RTX 2060 SUPER, RTX 2070 SUPER and RTX 2080 SUPER) around June 2020, and its “highly anticipated” next-generation GPUs, the RTX 300 series, were to be released that fall. Moreover, Intel, around the same time, was set to release the 10^th generation of its CPUs, the lawsuit adds.

As a result, consumers had little incentive to buy Dell’s pricey—and soon-to-be outdated—Area 51M R1 laptop, the complaint says. To address this problem, Dell had to quell buyers’ apprehension—and did so by representing that the Area 51M R1’s core components were fully upgradeable, the case alleges. More specifically, Dell highlighted in its marketing for the Area 51M R1 the machine’s modular design and desktop-style CPU socket, which consumers were told allowed for the laptop’s core components to be easily removed since they were not permanently affixed to its motherboard.

According to the lawsuit, Dell “intentionally omitted” material facts in its marketing for the Area 51M R1 to conceal the truth about the machine’s upgradeability or lack thereof:

Consumers were misled by Dell’s false and misleading marketing campaign and paid a significant premium for the Area 51M R1 under the incorrect belief that this ‘unprecedented upgradability’ would save them money in the long run by allowing them to upgrade their laptop’s Core Components rather than having to purchase an entirely new upgraded laptop. Indeed, some paid approximately $5,000 for the Area 51M R1, specifically relying on Dell’s material representations that it was upgradeable.”

Per the case, Dell, roughly a year after the Area 51M R1’s release, unveiled the Area 51M R2, which carried the latest Intel 10^th generation CPU and NVIDIA RTX SUPER 2000 series GPU.

Who’s covered by the lawsuit?

The lawsuit looks to cover individuals residing in Alaska, Arizona, California, Hawaii, Idaho, Montana, Nevada, Oregon and Washington who bought a Dell Alienware Area 51M R1 gaming laptop at retail for personal use and entertainment and not for purposes of resale and/or distribution since the release of the product in 2019.

The suit also looks to represent a “subclass” of individuals residing in California who fit the above criteria.

What if I don’t live in one of these states?

If you don’t live in any of the states listed above, you may want to reach out to an attorney in your area. It’s possible that another case could be filed in the future and look to cover a more expanded group of Dell Area 51M R1 buyers. Learn more about how to start a class action lawsuit here.

How do I join the lawsuit?

There’s generally nothing you need to do to “join” or be considered included in a proposed class action lawsuit. These types of cases almost always take some time to work their way through the legal process, usually toward a settlement, dismissal or binding arbitration outside of court. This means it could be a while before the time comes for those who are covered by the case, i.e. “class members,” to file a claim for whatever compensation the court approves – and that’s only if the case gets to that point.

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