Actually indeed it IS VERY likely that that will be the way. As much as ATI wants to stay away from that solution, they and Intel have both stated (in their BTX release) that the new PCI-EX cards will likely need to send hot air out of the system. The new CPUs and VPUs are going to produce MASSIVE amounts of heat. And while the AMD64FX is about 70% the heat production of the ~150W P4 3.4ghz EE (the 3.2 is about 115W), it will produce alot of heat. And so will the new PCI-EX enable monster VPUs (no thermal ratings on them yet , because VERY little info out there, heck little thermal info out there for OLD VPUs [AMD publishes their Thermal info, that is why it's commonly out there for CPUs & Intel only does it for products they think have direct competition and concerns]) In that environment it will be necessary to get cold air into the VPU/Memory and then hot air out. I'm sure both ATI and nV are doing all they can, but even they have stated that it will be tough. Look at the XT, it's already heading to a flow-esque solution.
Expect the R42X and NV40 to have the coolers on them similar to the FX5950U (not the FX5800U thankfully).
Now one can hope that the LOW-K 0.13 process for the R42X will allow it to use an R9800XT style cooling, and that would make sense with the type of cooling used by the R9600Pro/XT. The thing is they would likely 'underclock' the card to achieve that and therefore moders may see the same benifit of the R9600s in overclocking.
Anywhoo, this is all conjecture beyond the fact that ATI and Intel said that future PCI-EX solutions will draw alot of power and generate alot of heat which will need to be removed from the case. If we're lucky the new form factor with do the job without the leaf-blowers.
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