If he is not going to overclock them himself, I would recommend him stay away from the factory overclocked cards as well as they are not as reliable, draw slightly more power, and run hotter than the stock variants.
My experience:
There have been a small number of times when I bought the factory OC version and DID NOT overclock it at all, and the thing blue screened or showed artifacts. This tells me that the technicians at these companies are stress testing the cards, but not controlling the temperatures when they do it; so they sometimes send out damaged cards. (However, this was only experience with two specific brands).
However, when I have purchased stock cards and overclocked them to OC specifications and then stressed tested them myself they have always worked perfectly. So I avoid the factory OC cards. I repeat I have had factory overclocked cards die early or show artifacting right out of the box, but cards running at stock speeds which I have carefully overclocked to OC specifications have never had problems.
I've just made it a rule to stay away from factory OC cards, unless they just happen to be the only ones the manufacturer is offering at the time.