On the Fram test video at around 5 minutes in I just noticed the can itself moves down, according to their picture, which breaks the gasket seal and it leaks at around 350 psi. The can doesn't burst. The baseplate is fixed at the thread so the baseplate must flex out. Maybe that's why some filters have very thick baseplates.
https://www.youtube.com/watch?v=cttLaWepdL0
https://www.youtube.com/watch?v=cttLaWepdL0