One less key to push
So you're using Safari. You've enabled tabbed browsing (who wouldn't?). You have a two-button, scroll-wheel, wireless Microsoft optical mouse. Using the Microsoft Intellipoint mouse software for OS X, you turn the clickable scroll wheel's command function from Autoscroll (the default) to Command-Click. Now you don't have to hold down the Command key while clicking links in Safari to get them to open in new tabs...