Honestly, none of those things cools enough for me. If you feel like you'd like a little challenge, then try this:
1. Buy a full copper rackmount cooler, that handles up to P4 3.2Ghz+ or Athlon 3200+ or Athlon64 3400+
2. remove stock heatsink
3. put the rackmount heatsink on the desirable position which you wish to mount it at.
4. Get a Pencil/Pen and flip the card over(heatsink still at the position) and put the pencil through the 2 stock mounting holes, make a mark on the heatsink through each hole.
5. Get a drill, drill the 2 holes on the 2 marks on the heatsink, keep drilling 'til you went through the base, don't drill the fins.
6. Get some 2 screws with knots, and some industrial epoxy, now fill the holes you've drilled with epoxy, then push the 2 screws in there. Leave it 'til its dry, it'll be about 10 min.
7. Now put some industrial epoxy on the 9800pro's shim, and a fairly thick layer of thermal compount, Arctic Alumina, or Arctic Ceramique whichever you perfer.
8. put the rackmount heatsink on your video card, push the screws through, and use the knots to secure them.
9. Now get some strings or wires, just something strong and bendable.
10. This is a little tricky, just tie the heatsink, use the holes near the top of the card and tie a knot somewhere on the back of the card.
now you got 3 ways securing the heatsink, it will be secure. It may be a little heavy with a copper rackmount cooler, just make sure you screw it in tight when installing the video card.
There is a bit risk involved, since this process will void your warranty, however your cooling will be improved by more than 100%. This is kinda risky but effective, you can try it if you're up to the challenge. I've personally did this to my FX5900, and it's working great.
<A HREF="http://forums.extremeoverclocking.com/myrig.php?do=view&id=17301" target="_new">My PC</A>