We find a limit cycle in a quasi-equilibrium model of evaporative cooling of
a two-component fermion gas. The existence of such a limit cycle represents an
obstruction to reaching the quantum ground state evaporatively. We show that
evaporatively the \beta\mu ~ 1. We speculate that one may be able to cool an
atomic fermi gas further by photoassociating dimers near the bottom of the
fermi sea.Comment: Submitted to Phys. Rev