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Active vs. Passive Heat Sinks
While it may seem that an active heat sink is "obviously" better than a passive one, it is not always this simple. An active heat sink does in theory cool better than a passive one in a typical system. However, many large hardware manufacturers, even top-rated companies, use passive heat sinks even on high-end machines, because they have certain advantages over CPU fans:
In addition, newer systems using the ATX form factor motherboard and case already have a (much larger) power supply fan blowing over the processor. If a good-sized passive heat sink is used, the power supply fan often provides enough air flow to ensure adequate cooling. In a standard AT system this is rarely the case however because the design is totally different.