I have an aggressive fan curve set for this which works well when the GPU is around 50% usage, but once it starts approaching 80-100%, the temperature continues rising even with the fans at 100%.
I found that while playing Bioshock: Infinite, in-game GPU usage stays around 50%, but alt-tabbing to the desktop puts it at 100%. I sat and watched the temperature make a steady climb to over 90c and into throttling while the fans at 100% had no effect.
Not overclocked, well-ventilated, etc. The case is actually right beside a central air vent, so this makes no sense.