How Dell dodged a class action suit over Alienware Area-51m GPU upgrades


But it turns out Dell never had to meaningfully face that lawsuit. Area-51m buyers never successfully banded together in a class action case. Dell was able to force them into binding arbitration, I found, when I went looking to see what happened to the suit.
Regardless, some Area-51m owners went on to win settlements in individual arbitrations, their lawyer, Steve Hochfelsen, confirmed to me. (He’s one of the partners who brought the prospective class action lawsuit in the first place.) We can’t tell how much they won or whether the plaintiffs had a great argument because settlement terms were confidential. That’s typical for these sorts of cases.
It’s a very different company with a very different idea of what a modular GPU should be, and at least one of the key players behind the Alienware Area-51m — Alienware co-founder Frank Azor — is working with Framework to help it learn from Dell’s mistakes. He admitted to me that “the promises made were not kept” with the Area-51m. (He left Dell before those GPU upgrades could ever ship and now serves as AMD’s gaming chief.)
Since neither Nvidia nor AMD has promised that they’ll make future chips compatible with that format, Alienware can’t promise future upgrades either. The company thinks it’s likely that future GPUs will be small enough and draw little enough power to fit on a DGFF board, but it can’t say for sure.
The company’s marketing definitely suggested it would happen, though: “GPU upgrades can be done with GPU upgrade kits available on Dell.com.”
But while Dell did eventually offer “upgrade kits” on that website, they weren’t actually meaningful upgrades: just the same GPU boards you could have already bought preinstalled on day one. I suppose Framework could get off on the same technicality if push comes to shove. “We are committed to making sure there are graphics modules beyond the initial launch,” CEO Nirav Patel told me.
I’ve never heard it confirmed why specifically Dell didn’t create a new set of GPU upgrade boards for the Area-51m. It could have been size or thermal constraints, both of which Framework’s design tries to address. But it could also have been that the laptop simply didn’t sell well enough to justify it. The Area-51m was an incredibly heavy, pricey laptop that required two large power adapters for gaming — though my colleague Dan Seifert also found it to be an excellent performer in his review.
“If customers don’t show demand for it, it’ll be a novelty and then it’ll fade away,” Azor told me in 2019 about the Area-51m’s GPU upgrade boards.
He told me something very similar this Monday as I chatted with him about Framework. “If people are not willing to pay, it won’t scale beyond this… we might see a generation or two.” But he thinks Framework might finally have the formula right, and I very tentatively do, too.
But it turns out Dell never had to meaningfully face that lawsuit. Area-51m buyers never successfully banded together in a class action case. Dell was able to force them into binding arbitration, I found, when I went looking to see what happened to the suit. Regardless, some Area-51m owners went…
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