Most of the 2800+ chips out there are older stepping Claw C0's and newcastle chips. I had a 2800+ newcastle for a little while, and had no luck surpassing 2.3ghz. AMD used bottom of the barrel silicon for those old newcastles. I think the later production date chips were a bit better, so I suppose 2.4 or 2.5 is possible, but you'll likely have to pump a LOT of vcore into them to get them to behave.
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I just gotta get my mobo to supply it, cause its there now.