That was my 1st conclusion, however I drew my conclusions too fast.
The Gigabyte cools better in the Guru3D article cause the measurements were made at waaaaay different clocks.
http://www.guru3d.com/articles_pages/msi_geforce_gtx_970_gaming_review,26.html
http://www.guru3d.com/articles-pages/gigabyte-geforce-gtx-970-g1-gaming-review,1.html
With MSI at 1325 clock, it hits a GPU temp of 68 C with PCB measurement points from 62C to 82C and a dbA of 39
With Giga at 1178 clock, it hits a GPU temp of 60 C with PCB measurement points from 57C to 61C and a dbA of 39
With Asus at 1114 clock, it hits a GPU temp of 69 C with PCB measurement points from 62C to 82C and a dbA of 39
The 1st thing we can do is knock out the Asus .... at the lowest OC of the three, it's the hottest and obviously at higher overclocks it would well exceed the 39 dbA
The MSI runs a bit hotter simply because they overclocked the bejeezes outta this card before they put it in the box. At a 12.5% higher overclock, it's quite obvious that the Giga would have to be much louder than it is an the "outta the box" clock.
Reading the techpowerup reviews for previous cards, I noticed that MSI puts much more emphasis on sound then temps. The fact that everybody cam in under 40 dbA makes it appear that the industry has a "target" and set clocks to that they wouldn't exceed the 40 dbA mark.
Their profile seems to be to keep sound as low as possible and not really give a hoot about temps until they approach the 80s....I anxious to find out what the relative fan speeds were at the time of testing.....given the fact that they all had the same sound level.