A most interesting question!
I would imagine that, at the very least, it would be adequate. There are a lot of things to take into account, though, and more than just the simple dimensions of the product at hand. How many fins will it have, will they be aluminum, and how will you "attach" them to the heatpipes? (How do you intent to build the heatpipes?)
Beyond that, there is the question of air optimization and heatpipe placement, but these are nuanced things.
Arguably the most important would be the base and the matter of mounting to the CPU. I think Xigmatek sells universal replacement mounting kits, if you could pick up one of those, that should be sufficient.