Depends on how you train and veg. I've done 12 in a 4x4 under 1000 and 6 in the same setup. With two weeks of veg both times the 6 are looking much nicer.
Under a 400 I would do maybe 3 plants with 2 weeks of veg, or 6 plants with no veg. Cramming plants doesn't increase your yeild unless you're doing some sort
of SOG.