Hypothetically, you could. I have no experience with reference 780s, for the record, but I've got a reference PNY 760 (worst mistake ever) and, although I don't overclock it because I want to sell it soon and want to be able to say I haven't overclocked it, I have a lot of thermal room. However, I only get this thermal room if I blast the fan at 100%, which I don't mind since my gaming headphones are sound isolating.
My point is that, if you don't mind manually turning the fan up higher than speed%:temperature, then yes, you can achieve higher than reference clocks. My gpu is about 10-14C lower than it was at normal fan speeds.