Ars recently tested SteamOS against Windows 10 and determined on average Windows 10 had a higher frame rate.
Does this have anything to do with Linux's reliance on an archaic graphics system (X11)?
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I'm pretty sure that Nvidia drivers bypass X system almost entirely, in a similar way as Mesa drivers use DRI.
You will be able to measure the X11 overhead (if any) once Nvidia starts to support Wayland in their drivers.