Quoting my response to Tuna-Fish:
"Trying to overpower the transmission of the BT peer is certainly the technique to take (although I was hoping not to broadcast that publicly in my original post). You will still have a tough time, however, because you're probably trying to overpower the transmission of two collocated devices (e.g. keyboard+computer) while you are 5-50feet away. In many cases you'll probably end up saturating the receiving antenna. It will be largely a trial-and-error technique, but it will work eventually."
This attack should be possible from any software-defined radio that's capable of sniffing on and forming BT connections.