The owner of the Alienware Area 51M R1 gaming laptop claims that Dell intentionally misled him, in an action complaint in front of the US district court of Northern California with advertisements about "the unprecedented upgradeability" of the laptop.
The 20-page complaint alleges that Alienware "falsely misrepresenting characteristics and qualities of the Area 51M that it knew did not exist," claiming violation of the California Civil Code contract and guarantees, false publicity, and unlawful commercial practices.
The suit filed by plaintiff Robert Felter alleges that Alienware's advertising misled users into believing that owners of a 2019 Area 51M R1 laptop could upgrade to future Intel CPUs and Nvidia GPUs, such as the then-upcoming Intel 10th generation and Nvidia RTX Super GPUs.
With the Area 51M R1, neither was possible. The Alienware Area 51M R1's Z390 motherboard couldn't support 10th generation Intel CPUs because they switched to a new socket. Dell eventually sold GPU upgrade kits for the R1, however, they only supported the RTX 2080, not the faster 'Super' models, thus anyone who had already purchased the laptop with an RTX 2080 was out of luck.
The Area 51M R2 was the new version of the laptop, and it included upgrade kits for the Super GPUs as well as Intel's 10th generation CPUs.
According to Felter's lawsuit, Dell knew when it promised "unprecedented upgradeability" that the 51M's upgradeability would be limited due to factors such as the Z390 motherboard, and that it was a marketing tactic to help sell the 51M before newer hardware became available. The suit states, "Dell knew it had to address consumers’ hesitation to purchase the Area 51M R1 shortly before its Core Components became outdated."
"Dell’s advertisement to the public didn’t place any restrictions on the upgradeability of the laptop," a lawyer for the plaintiff told Tom's Hardware, adding that Dell "never disclosed that those with the highest spec CPU and/or GPU that their device would not be upgradeable."
You may read a copy of the complaint here.