In some cases, it would be nice to update the top N items as part of a update query rather than having to retrieve all items and loop through the top N items to update them. For example, if I have 1000 customers, but I want to only apply a discount to those top 10 customers having sales over x amount, I would currently have to do a Find to retrieve all customers matching my criteria and then loop through and update the top 10. A cursor gets me part of the way, but still seems like a lot of overhead when I want to do just an atomic update.