Couldn't? Or wouldn't?
I've seen lots of users unwilling to go above a certain voltage limit, or heat limit, or noise limit. And certainly those are considerations that could be very important to certain users. I wouldn't expect the same percentages for those individuals.
For those users who are determind to reach their OCing goal, these other considerations take the back seat.
For instance, how powerful was the fan you were using? What is the highest core temp you were comfortable with? What was the highest voltage you tried?
I've got what is one of the worst clocking 920s I've ever seen, it took 1.45V to get 4.2GHz stable, 1.4V to get 4GHz. Since it's in my daily gaming rig, and noise & power consumption are important to me, I backed it off to 3.8GHz for 24/7 ops. This does not mean it's not a 4GHz chip, only that absolute performance is not the to priority for this system.
I'm not trying to knock on anyone....simply being realistic