i do about three or four under my 250 watter without too many issues.. i tend to grow bigger sized plants in either a five gallon or a three gallon pot..
if you do smaller sized plants in six inch pots, you could fit 36 or so in a 3x3 area.. if you go this route, i would recomend starting from clones, and once rooted, give them a weeks worth of veg time, than go ahead and flip the lights to 12.12...