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Depends on what the case is. For example the PS4 doesn't have a ground, but the case is made of plastic and is isolated from the power supply. The air vents are positioned in a way that makes it difficult to access the inside.


If it is a bare metal chassis:1

If it is an anodized/powder coat but well ventilated case:4

If it is an industrial passive case:8 (not bad at all)

If it is completely non conductive, isolated chassis, double isolated power supply: 10 just dandy