We've been through the background: silent air cooling is a great match for devices less than a quarter of an inch thick (fans become very inefficient when they are that thin). But such thin devices are almost all surface, so they hadn't had significant heat problems.
Today Consumer Reports stated that the new iPad reaches 116 degrees while gaming. And Apple tends to do the best engineering around, so others aiming at the same performance level figure to have bigger heat problems.
You think the cooling market might get bigger than Tessera anticipated?