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Yeah some people have poor case ventilation/airflow and some don't, it can have a big say in how cool and quiet a card runs.
I dont understand this noise problem...I find the GTX470 much quieter then my HD4870.
Pretty sure this is just your assumption, or you are thinking some cards with crap cooler. Gigabyte's cooler is quiet up to 70% fan speed, and only start to become 'noticable' beyond that according to people that have it, and I don't see the GTX460 will become as hot as you claim, considering the GTX460 can reach 800MHz on stock voltage.
I seem to remember 4870s ran almost as hot as the GTX 470 anyway.
So it's ok for GTX470 to run hot and be noisy because HD4870 did it as well?![]()