Win9x specifically remembered last used window position for console window if I recall, like many desktop applications today do and save the position in their config file (or registry).

Win10 has system-managed option (which I guess is equivalent as if you passed CW_USEDEFAULT to CreateWindowEx's X and Y parameters if you are making your own graphical application calling Win32 API directly) for window position or you can set the fixed position. Minor detail, but not equivalent to remembering last position.