In that case then you are definitely going to want to get her a card with a non-reference cooler as it will most likely cool better.
You may want to try the MSI N550GTX-Ti Cyclone. It has excellent cooling.http://www.newegg.com/Product/Product.aspx?Item=N82E16814127573
In the last generation of cards AMD typically ran cooler. However if she is in to WOW she is definitely going to want Nvidia as their cards perform better in most of the World of Warcraft benchmarks I have seen.