Outdone what? They prove they can up a FSB far enough to run Super Pi 1m? The skill in overclocking is stability.
I may be an idiot, but I only use SuperPi to find the obvious instabilities. If it fails 1m, you are lucky to even be in Windows. If it fails 32m, a setting needs to be adjusted or the oc backed off until it passes. When you find your max on 32m, then you let Orthos or 2 instances of prime run for a minimum of 8 hours, 24 more like it. Then at that point you can proudly say that I'm faster than you.
You can out stable someone the higher your speed goes. Someone running at 3.6 100% stable is better than someone doing a suicide just to see how high they can boot.
The C2D's are so brand new, noone can safely even give a guess as to what voltages they can take long term. As the extreme overclockers chips start popping...we'll know soon enough.