Temperature
We've come a long way, but we've finally found a way to separate the two head-to-head competitors. NVIDIA's reference cooler on the GeForce GTX 560 Ti is good, but the Vapor-X employed by Sapphire on the HD 6870 TOXIC is simply phenomenal at keeping the pre-overclocked Radeon temperatures in check.
Keeping under 70°C while gaming is impressive, but the low temperatures do come at the expense of noise.