I would always go for the Gainward Golden Sample with the great custom cooling. They always put a little extra customization into their cards and the Golden Sample means that they select higher quality components to ensure solid overclocking.
"Gainward designs in only the highest quality components to ensure excellent stability at extreme conditions. High quality low-ESR rugged solid-state OS-CON capacitors are used to improve overclockability and robustness even at critical environments."
"Gainward Grand-Prix Heat-Pipes Hybrid Cooler, was designed in 6 mm copper-water heat-pipes on a copper base conducting heats away from GPU at highest efficiency, then dissipating onto aluminum heatsinks, which are forced ventilated with Great 8 cm double-ball-bearings Fan (GR8) Achieve highest cooling performance at much lower temperatures under power saving mode and full load with much quieter operation noises than reference GTX 460.
"Gainwards GS version differs from the standard cooler by having a higher specification fan in a centrally mounted position. Unlike a lot of non-reference designs the Golden Sample keeps the shroud that exhausts the hot air out the rear of your case, benefiting your whole system."