If it's not stable that headroom is useless. C2Q processors have way more headroom that current Phenom II and you know where we are now. Also I'm currently looking for OC results in the AMD section. If you read them carefully you'll see that up to ~3,6GHz almost everyone is "stable" at stock volts. But if you keep pushing the required voltage goes through the roof with TDP and power consumption following it. Does that tell you anything?
EDIT: Well, more like ~3,4GHz...





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