Let me counter with this question: Why would any legitimate user need more than X attempts within N minutes to log in? If they know their password, one attempt should be enough. If they don't, there's always the "forgot password" link that all good sites (should) have. A few attempts should be given in leeway for those like me who have many passwords and bad memories, or for those who have issues with typos.
If you don't want to do it without good reason, then I recommend you keep a sharp eye on your HTTPD logs. Of course, by the time you recognize there is an issue, the attacker may have already succeeded. Which brings us back to the "why not just do it" argument.
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It's all fine and dandy until someone has to look at the code.