I think 4 could. 2 in the section 1, turn 90 degrees out board, slap 2 more on before it exits out the side.
Fyi: I saw an interesting, but old, thread on m3f in the e46 m3 section. It's like a rear trunk floor/ strut reinforcement brace, welded in. Pretty neat, even with a cage it seems like it makes sense.
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