PasswordA SomeOtherPassword1 PasswordB SomeOtherPassword2 PasswordC SomeOtherPassword3
Just iterate on every other change, and you've beaten the requirement.
For example, if a user's first password is "first123!@#" and their second password is "second456$%^", there are no letters in common—but those two passwords, when joined together, are very intracompressible (by an ideal compressor)—and likewise, an attacker who knew that the first was a previously-used password would be very likely to try the second. That both properties apply is not a coincidence of this particular password; the intra-compressibility of a set of plaintexts, and the predictability of unknown plaintexts of the set from known ones, are equivalent measures of informational entropy.
Compression systems typically need a lookup table of some kind and have more overhead than just the raw comparison.