There is a bound well before that which is reached in heating material (i.e. sidestepping the borderline philsophical debate as to whether the early Universe could have gone thorugh a hotter phase) - the Hagedorn temperature, where energy loss through production of particle/antiparticle pairs throttles further heating. I seem to recall it's of order 10^10 K.
Hmm. According to
this article, one can think of this as a melting point for hadrons into quark matter, and rapid enough heating can cause the quark motions to increase, so it's not as absolute as it once looked.