The memory/memory controller cold, memory overclock limit doesn't exist on the GTX's Sascha.
Most of the times you can also clock the mem's higher on LN2 compared to your max on air.
The hate could be about the cold slow bug ( under a specific temp, varies from -70C to -85C from card to card, the card slows down ( throttles and performs like a GeForce 2 MX ) ).