If he's got a case like my buddy's HP, then not really. His case is one of those smaller reverse ATX cases (opens on the right rather than the left). He was having minor troubles with heat in his case because the thing only had one fan in it other than the PSU fan and no room to add another. What we did was add three 40x40x20mm fans to the side inlets. It only worked just well enough, but it worked. When he decided he wanted a video card, I told him that he can only have a blower style card cooler, no mid-mounted fan jobs. It has been working well for him, thus far.
Hmm I see. That's why I always profess the virtues of building your own pc. Nothing beats a custom case design. For hot running video cards (or multiple video cards) you want quite a few fans - as big as possible to keep the noise down yet maximize CFM.
I'm wondering maybe he can setup some sort of ghetto rig...cut a hole in the side of the panel and attach a 140 mm fan there..or two.
Do you have a pic of this case?