I think you shouldn't test oc cards vs stock cards in some situation certainly.
The 980ti cards are 670 usually and the fury x is 650 or higher as well. So I really see no issue using an aib 980ti card that's 20 over the msrp. It's what the vast majority of people care about.
Using a 980ti reference card that very very few people are interested in, in a test means nothing to me. Show me the $670 980ti that are vastly superior that's what matters to me. The only reason people are whining is because it makes the 980ti look great.
Is it unfair if people don't use amd cards that are aib models when it makes sense? Sure... But we should tell them to make their tests better. Not to make other people's tests worse because we're mad at some "slight" from years prior....
It's more about consistency than anything really. I want a test that includes the reference models because it's exactly that... a reference. It's the starting point. If you're going to include an overclocked version, include the reference card, too, so the readers can have a better understanding of how each cards stands relative to one another. Plus, we can compare it to other reviewers to get an even better understanding of the cards' performance. Chances are, other reviewers won't have the same aftermarket OC'ed card in their reviews; but, more than likely, will have the reference design. That's it.