GPU Heatsink Orientation

[Totally Average Gameplay]

I tried looking on the internet about Vertical GPU heatsinks vs Horizontal ones but Google decided to mess with me and give me GPU mounting and CPU cooling.If you do not know what a Horizontal GPU HS, it looks like this

 

And Vertical GPU HS is this

 

 

I haven't seen a high end GPU having a Horizontal HS, its always vertical no matter what AIB cards you look.
Vertical HS blow air into the case and warm up other components like the motherboard, which I think is counterintuitive as a cooling solution; cools the GPU but affects the surroundings
Horizontal pushes air out of the case like the Blower style cooling.
But why tho?

[Jurrunio]

At the same time, having horizontal fins means the heatpipe dont stretch out straight and can't spread the heat as evenly to the fins as vertical fins and straight horizontal heatpipes can. The general consensus seems to be thicker heatsinks use vertical fins (they have enough room to let air escape to horizontal directions), thinner heatsinks use horizontal fins (because they dont).

[Totally Average Gameplay]

Can't they just combine the 2 designs?
Waste heat goes out the case + using thicker pipes and heatsinks?
Or is there anything that I don't know that prevents it from happening?