I just purchased a used Dell Latitude E6400 on eBay.
It came without a hard drive, so I put in a brand new hard drive.
The laptop had a valid Windows 7 Home Premium license, so I installed it and validated it using the product key located on the COA.
Then I upgraded from Windows 7 Home Premium to Windows 10 Home Premium.
But I wasn't able to update the BIOS from A11 to A34 (latest version) or even A20.
I even ran Compatibility Troubleshooter.
The Windows registry modification suggested elsewhere was not helpful.