If the GPUs have ACX-style (2/3 fans on the face) as opposed to reference (do they call it "Founders Edition" now:/) design, they expel hot air back into the case, so it's all about having massive airflow through the case to expel heat. The reference design, for all its efficiency drawbacks when compared to ACX, at least expels hot air outside the case through the back of the card.
Opening the case as suggested might help. If that is not practical for continued use, you'll need to re-examine your case fan placement and speeds to make sure you are moving lots of air through the case. Even then, the primary card will probably always run hotter due to constrained area in front of the fans.