Well, I've put almost every decent 10" sub that has a mounting depth of under 6" into WinISD and analyzed SPL levels it came up with, and the Treo TSX 10.22 and Memphis M3102D come out on top, by quite a bit. Each and every driver was analyzed with same enclosure, and with either 400 or 750 watts, depending on RMS rating, and build quality.
Both are roughly the same price, both can be wired down to 1 ohm. Both are also available in D4 configurations, so I can still get 1 ohm if I decide to go with 2.
I would go with the TSX because the build quality of that woofer is INCREDIBLE.
B was throwing an Orion2500D to each of his TSX's DAILY. I'm pretty positive he never fried them either. I would feel safe giving them around 1000-1200 watts. Try putting 1500 watts on the M3 and watch it burn.
I agree with Reece. The TSX would most likely be the better choice. I have heard good things about them and I believe the build quality to be better than the Memphis also.