I don't think I can go higher on the core and maintain good thermals (would need higher voltage and I'm using a case).
Try running 3 non-reference cards in a closed case and you'll realize it's not entirely a misconception. Also, miners don't buy cases because it's cheaper to not use a case; that and cards tend to run cooler (the room essentially becomes the case). Unless your deaf or not sitting next to a 3+ card super computer, it's not as easy as buying more/bigger fans to push in/out air.