Okay, from an upgrade standpoint, a "catch up to performance" step, I can understand it more.
However, that's not how it's marketed most places (almost always 2 highest-end cards in SLI), and I've read a couple of articles where folks did that but had trouble finding the exact same card a couple of years after the fact, so they couldn't run it properly in SLI.
Definitely a strategy of sorts (planning for future upgrades) but not without peril.
As an aside, I personally wonder if there's much price difference in motherboards, all other features being equal between SLI and non-SLI.
[EDIT: On second thought: Using SLI to keep up with the curve isn't going to help much, if SLI doesn't increase FPS much for that extra card. Your price-per-fps might not be worth it. (*shrug*)]