Could be but I think it would be something bigger...phase change, TEC, or water cooling but I think it is a water cooled setup. I can see phase change and one of those unreliable tech sites rumored phase change but i don't see dell's R&D creating a phase change unit they can support indefaintely. There are inherenent issues in phase change technology and isn't really "bulletproof" for the regular Joe who buys the fastest Dell on the block with this type of cooling. Even experienced phase change users had issues such as maintaining the compressor, keeping condensation out of the block and CPU, etc....TEC is a possiblibity but HARDER to upkeep and support on a broad consumer level Dell wants to do it under unless they create a specialized support team JUST for this unit and this unit only; might even need to create an on-site team/contractors just to diagnose problems with it. Water cooling is probably the easiest to support on and off site not to mention the safest out of the three cooling methods that everyone is suggesting. There is ONE more possiblity and that lies in a very slim, TEC (maybe phase change, not sure) unit that can be fit inside a case just for the CPU. It was released earlier this year around mid summer/early fall and seemed like it had a promising future. Forgot the name of it. It retailed for around 300-500 from what I recall but like I said I'm not 100% sure. If anyone can find the link for this product or if I find it I'll post it on here.
We'll see when they officially unveil it...
EDIT:
found what i was looking for..this is that slim, all in one TEC/peliter unit I was talking about earlier...
http://www.crazypc.com/products/938200.html
could be next best thing to the water cooling that Dell might introduce...