do you mean "next" to the ram when the case is laying down and the mobo is flat, then "under" the ram when the case is stood up, blowing upwards ?
If so you might just get an inexpensive spot cooler (like antec) and use that, instead of attempting to clip things to your ram.
If so you might just get an inexpensive spot cooler (like antec) and use that, instead of attempting to clip things to your ram.