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^ yep..
Of course it can be a heatsink...
Most black box LEDs just use an aluminum plate that has no fins at all..
If its sufficient or not for your build depends on the specifics of your build..
It will easily handle all of those LEDs in the back of picture 1...
Being a "good" heatsink is about surface area.. A flat plate by itself doesn't have nearly the surface area of one with tons of fins/pins or whatever...
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Who me?
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