MSi supposedly increased their quality of service so I'd side with that.
Mostly i buy from EVGA, BFG, XFX when i buy for my self
EVGA has a 90 day trade up program
BFG has life time warranty and 100 day trade up program
XFX has double life time warranty good for re-selling, as it transfers over to the person who bought it from you. And the warranty covers dmg from oc as long as you didn't modify the voltage although most cards are sold pre oced to a good point
for others i've used products from MSI, PALIT, PNY, Galaxy, HIS. If you're gonna have to deal with customer service usually buying the card with the best service is a good rule of thumbs.