That's only if pulling air out the back of the chassis is an issue, which is inherently linked to the orientation of the HSF. As with mine the Xigmatek points upwards towards the 120m far on my OCZ PSU. Which isn't all that bad. Alternatively there are cases with the PSU at the bottom and venting at the top again making this orientation fine. Last I checked Hot air has the tendancy to rise, so with a setup that allows for easy ventilation out the top, it DOESN'T suck.