With no will to offend those more knowledgeable, I invoked the second law quite simply to illustrate the willingness of the more 'heated' object to 'give away' its heat to the colder one (in this case, air), and how this 'willingness' decreases rapidly as both objects near the same temperature. The constant tendency towards a temperature 'equilibrium' in the environment. 'A touch general' oh very much so, but sufficient for our purposes, to note that it takes exponentially increasing amounts of effort to make HSFs more efficient without modifying the ambient environment. Eventually up to the point when further refinement of current approaches simply become unsustainable, giving way to innovation and industry shifts towards superior solutions. Without mainstream innovation you end up spending loads developing a product granting only minuscule gains.
I took extra care to include words such as 'conventional' and 'reasonable' precisely to exclude radical/expensive/unmarketable/impractical/unavailable etc. solutions/improvements that could potentially push the limits. The ones mentioned are, of course, valid and will improve future products, albeit once again only increasingly slightly (do you see, for example HSFs cooling better than custom water any time soon?), or am I incorrect in assuming the OPs intention to question the present state of things, stuff that's out now ?
The market is relatively slow at introducing new things, it has to be incremental. Partly due to the nature of existing hardware (compatibility), partly due to affordability and also the maximization of profit from a corporate perspective. It's quite clear that 'conventional' HSFs, the traditional ones, the ones with a fan, a heatsink, pressure mounts, thermal compounds, copper/nickel plating will be around for a while longer. The intrinsic thermal properties of metals and their cost is another limitation that comes to mind as well by the way. (let's not delve into alloys and alternatives to solid metal)
In short, most things considered, it's exceedingly hard to bring temps down. My main point, indeed a reply to the OPs question, goes something like this:
You can have this expensive 'brand' case which will keep your temps as low as 34* idle. It costs 250 pounds.
Or, assuming all other things being equal, you can have this rubbish case for 30 quid which will keep your temps at 38*.
Of course the above is purely arbitrary, the numbers are made up and it has little relation to reality, but the principle stands, you might quite possibly end up paying in excess of 200 quid extra just for that relatively minor 4* gain in temps purely because of the diminishing returns involved in pushing it just that little bit more. Or worse yet, as with some of the more stylized and insanely overpriced cases, actually suffer less desirable temps than even the cheapo offerings. However, whether companies are justified in charging us that much for cases is another matter entirely and therefore irrelevant to our present discussion.
I merely attempted to go slightly beyond saying 'yeah it doesn't make that much of a difference considering the price difference', slightly beyond by illuminating some of the potential reasons as to 'why'.
Or did I just make a stupidly simple point in a bizzarely convoluted manner ?

If so, I do humbly apologize...
- Ordokai