You assume way too much. Not everyone has properly cooled cases with great airflow that is controlled to provide better cooling than an open test bed.
Listen, the point is, for $100 extra, Nvidia provided a substandard cooler that throttled.
Last generation, in the same price class, AMD provided a watercooler, free of charge, on the Fury X, that did not throttle, and had great temps/noise.
Nvidia is getting complacent by offering WORSE cooling on the GTX 1080, than the GTX 980, while charging more money than the GTX 980, and while offering less overclocking gains with the GTX 1080.
To let the GTX 1080 truly shine, Nvidia needed to provide a proper cooler, a proper BIOS (Since high OCs are only obtainable on different overclocking BIOS that the LN2 crowd are using), and proper power delivery. Without all of that, the GTX 1080 got released with not only an inadequate cooler, but also other issues which amounted to just OK stock performance in REAL WORLD CASES, and poor OC capabilities.
That's a shame for Nvidia's current flagship product.
A flagship product should be a premium product. Not this, and not this especially in the cooling department. Throttling is not acceptable.