I wouldn't doubt if it'd cause heat problems if it's literally resting on top of the other hard drive...not only do HD's get hot on their own but having another hot hard drive resting on top of the other preventing it from getting air isn't such a good idea...beyond that I wouldn't want to rest two on top of each other regardless of heat simply because on most hard drivers theres circuitry exposed on the bottom part, and I wouldn't exactly want that resting on the nice electrically conductive metal top plate of the HD below it