It depends how high you plan on overclocking your RAM, and whether the 6400 can reach the speeds you want.
If you have a CPU with a higher multiplier (or a mobo that will let you unlink the RAM like a 680i for example) and your RAM won't be pushed too high above 800, then the 6400 stuff should be fine.
But if you plan on pushing your RAM alot due to a lower CPU multiplier or mobo that won't allow unlinked, then the higher rated RAM speed is better because it's guaranteed to take the overclock speeds.
So it entirely depends what your ultimately OC will be on the RAM.
Post:
1) your CPU
2) your mobo
3) you intended overclock speed
4) what brand RAM you're looking at
Then we should be able to confirm for you.