I would disagree. I have seen some D0s that overclock pretty damn well. So far, I havent seen one that doesnt.....please prove to me otherwise.
So far you've seen a bunch of hand picked ES chips. i7 overclocks are hard to watch too because people pushing them higher tend to disable HT to get lower volts/temps and a bigger e-peen. Most people will aim for 4GHz with HT enabled on a 920 and whether it runs that speed at 1.3v or 1.4v they won't really care. 3841A, 3842A and 3844A C0's all OC very well on the whole, all requiring less volts than earlier batches, but just because intel improved their process a little in these batches doesn't guarantee that the D0 chips can improve any further.