I have an idea for a case (built from scratch) that will lie flat and be cooled only by air. It should have so much air passing through it that it would be able to do some really good o/c'ing. Just looking at sketchup and i'll try to make up a lil design for it. Oh btw...this would require a custom-made HS and no actual cpu fan.
Edit: Maybe a small cpu fan which would double as a blower to the ram.