DX9 is like 10 years old, which in computer terms means 1500 years.
I don't see the point of developing a game for DX9, nor the point of NOT using Windows 7.
Vista was suicidal, ok, but Windows 7 is really good.
Another thing is, that you will loose performance on multi-core systems in windows xp, and have a limited amount of RAM.
I think your GXT285 is ok for the game, the bottleneck in CoD right now seems to be the lack of multithread support for the main sim thread.
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Ryzen 5800X
32GB 3200MHz
AMD 6700X 12GB
Windows 10
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