If I'm going to remove the case and do my own modding, then all best are off. I want something working well out of the box. I have enough computers to play, and not enough space to put Frankenstein systems securely around the house.
Fair enough, but the RPI 5 also won't reach max performance out of the box until you add a third party cooling case on it, be it active or passive. N100 systems at least come with a case already on out of the box that let them reach max performance albeit with some noise.
And we're talking about tinkerers after all, which is the target market for the RPI. Parents won't be buying RPis en-masse for their kids from Walmart to use as their main computer for school instead of Macs, iPads, Chromebooks or Windows laptops.
Average Joes who aren't into tinkering, aren't daily driving a RPI as their main computer. It's a DIY toy/tool for those who want to tinker, learn and make stuff, so some added effort is implied anyway.
Yes, that's sold as a DIY computer, so getting it a case is a must. OTOH, I'll be honest and say, both the official cooler and official case for RPi allows it to run at full-steam, almost all the time.
I especially bought that passive case for my Pi, because it's destined to be a "tuck away server" from get go, and it's trucking along just fine. I'm adding services on top of it slowly, and it's not showing any signs of fatigue.
A2 card and faster SD support really makes that one shine, without adding hats on top of hats. Again, OrgangePi 5B has better hardware, but way worse support.
Not if you put a large fin block on it.