I recently purchased a ProStar notebook. At the time ProStar was running a promotion on the model I chose that included a free Toshiba 128GB XG3 NVMe drive (OEM version of the OCZ RD400) .
Since I was planning on getting a Samsung 960 anyway, I took the free Toshiba XG3 as a place holder rather than spending the money for another Samsung 950.
The Toshiba NVMe XG3 works fine, but using HW-iNFO64 I observed that it operates at a full 12 degrees Celsius hotter than a Samsung 950 pro in the same notebook (I took a 950 out of another notebook to experiment).
That's almost 54 degrees Fahrenheit hotter and I can actually feel the difference on my keyboard.
Under ATTO benchmarking, the XG3 exceeded it's (80 degree C) max operating temperature rather quickly (at the 4MB mark) and went into thermal trotting. This would likely not be a problem in a desktop with better ventilation.
I partially solved the problem by installing a copper RAM heatsink on the controller. However, I had to remove the label and thereby voided the warranty.
So even when Toshiba/OCZ delivers 3D Flash, I will likely stick with Samsung even if the cost is somewhat higher.