Windows uses TPM for Bitlocker. A very common scenario where TPMs get reset is BIOS updates (when a TPM is implemented in firmware).
AFAIK, Windows cheats here because it also manages BIOS updates. When an update happens, it takes extra steps to preserve the Bitlocker encryption key in plaintext, and re-seals it to the TPM after the update completes.
Apart from Windows, there are many setups that fail in fun ways: Kubernetes pods that migrate from one VM with a TPM to another one, hypervisors that mount a virtual TPM to VMs, containers or VM images that do Tailscale registration on one machine and then get replicated to others, etc.
Tailscale already did some attempts at cleverness when deciding whether to enable features using a TPM (e.g. probing for TPM health/version on startup, disabling node state encryption on Kubernetes pods), but there was still a long tail of edge cases.