sure. It really depends on how much better the 3rd party coolers perform. They weren't as efficient in the 7xx series, because those chips ran a fair bit hotter than these new maxwells. Trust me when I say this, a 970/980 with a nice 3rd party cooler will run so cool, I maxed mine out at 62C, that is while benching with an overclocked card. That's how good these coolers perform on these cores. Not sure exactly how much hotter a reference blower would be, but I'm pretty sure in the mid 70s. So here the 3rd party cooler would make more sense.