I wonder if it's a QA issue or firmware that makes a difference. My 1Tb WD1001FALS is in an ESata dock
and it's still quiet even when I'm backing up my system drive to it.
All I know is there is no shortage of refurb WD's around. I just think WD ain't what they used to be and I have used them exclusively for many years. Not that they are any worse than Seagate or Hitachi these days, but they used to be so much better. I know I am loving my Samsung.