I haven’t pushed mine to the point of getting the fan to run, but I prefer devices that stay silent during normal operation. I don’t know if 40°C would be audible “too often” or not. I probably would hate it if already having problems sleeping in a hotel room (or my own bedroom) with an audible fan running most of the night. Even worse, I think, would be one that unpredictably started and stopped.

It isn’t the starting and stopping of rotation that is a problem. A couple of mine barely run for a few seconds when the CPU temperature raises a bit, then stop. You can’t hear them at that speed, so it isn’t an annoyance. I wouldn’t even be aware of it except for occasionally catching one starting or stopping out of the corner of my eye.