Yes that's possible - some of those fan issues affected earlier GPUs like the 8800GT for example, and in fact BFG have made available a new BIOS to update the fan profiles.
I honestly think it's a mistake to buy a GTX 280 now - especially if you already had a DX10 card - NVIDIA is working on new generation cards and DX10.1 hardware support, mind you it's not a big deal, but I would save my money and wait for nex gen cards. There is a lack of DX10 games as it is and already Microsoft is planning DX11!
Also it's mistake to buy anything NEW - I always wait until buying something because chances are problems get discovered (defects, bugs, etc) and the company makes some changes and new chip revisions - so it's not a good idea to jump on something new right away!
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