In the process above, the lowest temperature attainable is obviously proportional to 
.  
In the  ideal paramagnet, as 
 is reduced the graph of 
 against 
 rises more and more steeply, 
going to a step function
at 
.  But in any real paramagnet, there is a weak coupling between the spins which means that they prefer
to be aligned with one another.  If we remove the external field, this coupling acts like a weak internal
field, and at low enough temperatures the spins will still be ordered.  The strength of this coupling is then 
what governs the lowest attainable temperature.