Well you never know.
You may hit a wall at 3.6 where even water wont help you. Although you can see how high you can get your FSB to boot and run some small doo-dads. And if you can get to 3.8 or luckily 4.0 then you'll probably need more sufficient cooling. Or just creative ideas.
When I was running the Coolit Freezone Elite on my i7 setup I was at a point in overclocking where I had to remove everything from my case in order to get enough heat dissipation off the chipset and keep components spaced out enough in order to get fans blowing properly in order to blow the hot air away from each component without restricting another fan from blowing the air to another component away if you get my "draft"
Having your computer outside of a case when overclocking is nice just for the sheer face that your GPU is throwing alot of heat. Especially when reasonably overclocked (just feel the plastic casing when your playing a 3D intensive game).
The unfortunate fact of having all your components external of a case is dirt, drinks, sneezing, god knows what can get on it. I never had a problem. Even had a cat who would jump on it and cause utter chaos..