Hardware Requirements and Market Control
A central element of Klein’s case focuses on Windows 11’s unprecedented hardware requirements. The complaint notes that many Windows 10 devices cannot upgrade due to requirements for “Intel 8th Gen Coffee Lake or Zen 2 CPUs and up, TPM 2.0 (Trusted Platform Module) support, 4GB of RAM, and 64GB of storage.”
The lawsuit alleges Microsoft has “actively blocked Windows 10 PCs released before late 2017 from receiving the Windows 11 update, forcing users to buy new laptops or desktops if they want the newest Microsoft OS.” Furthermore, the complaint states Microsoft “has actively sought to prevent workarounds to move ineligible hardware to Windows 11.”
Klein argues this creates a captive market for Microsoft’s AI ambitions. The complaint explains: “To run optimally, Microsoft’s AI must offload work from the cloud locally to neural processing units (NPU) installed in newer devices. Windows 10 devices generally lack NPUs.”
Financial and Environmental Consequences
The lawsuit details the financial burden placed on consumers and businesses. Those unable to upgrade face the choice of purchasing new hardware or paying for Extended Security Updates at $30 per year for individuals and $61 per device for businesses in the first year, escalating to $244 by the third year.
Beyond individual costs, the complaint addresses broader implications for businesses running specialized systems. The lawsuit states: “Numerous business-critical systems—including point-of-sale (POS) terminals and computer numerical control (CNC) machines—operate on custom software developed specifically for the Windows 10 operating environment.”
Environmental concerns also feature prominently in the legal challenge. The complaint warns of “an estimated 240 million PCs becoming e-waste,” noting that if stacked, discarded laptops would create “a pile 600km taller than the moon.”
