Yeah, most of the best aftermarket coolers also dump the hot air into the case.
Its easier to expel that air with a few 120mm fans than try and blow it all out the small gap in the back plate of a videocard.
Not to mention even the coolers that supposedly exhaust air out of the back almost never have fan shrouds that are tight enough to the PCB to actually accomplish that. They all dump heat in the case, some more than others but they all do it.