Unless ambients are insanely high the stock cooler is more than enough to keep it at under 70c or so. These cards run ridiculously cool especially without voltage control. I doubt that cooling will be the limiting factor for most people.
70C with the default auto fan profile? Don't think so. Perhaps at 100% but I don't think most people are okay with the noise levels at max fan speed for normal 24/7 usage. Benching is another story.
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