Maybe I was being improptu regarding the MSI cards, but they do have a reputation (the Frozr range at least) for very good o/clocking capabilities, plus my son has a MSI 6850 frozr in his pc and that goes like the clappers, plus they always sell for a premium on the MM. The coolers on these cards are very good. Also the coolers on the sapphire would "appear" to be virtually the same, and they seem to overclock extremely well too. Its all a case of giving yourself the best "chance" of a good overclock (as nothing can be guaranteed in this game) and the MSI and sapphires would appear to give the user the best chances of high core and memory overclocks.
Wrt the heat aspect, in my case it is VERY relevant due to having done a fair bit of benching of mine at loads of settings, if my temps go above 75c and up then I'll more than like black screen and crash. when raising the fan speed, to around 50% and keeping everything the same, this doesn't happen and the bench completes. So if I can keep temps low, say around 60c everything fine and dandy and I can give the card a few volts as it were, plus it means I can have a play around with it which I haven't done for a while