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It's not arbitrary at all.I mean, that seems to be the consensus, but accounting for newcomers that's about 30+ cuts no matter how you slice it.
Yet the cuts everyone predicts are usually just Pichu, Young Link, Piranha Plant and uuuuh Lucas I guess?, and that's it. Something doesn't add up.
But taking Smash 4 as a baseline feels pretty arbitrary to me. That game also only had all the characters it had because it was largely built off Brawl.
The reason people use Smash 4 as a baseline is because that game gave us ample additional content alongside a sizeable roster of about 50 characters, something that even at the time Sakurai considered a feasible upper limit. Ultimate then went and gave us 76, seven of which were echo fighters, and we got almost no substantial single player content outside of Spirits, with longstanding, nigh-ever present modes either cut entirely or added as DLC updates.
Smash 4 also had the hurdle of developing for two consoles simultaneously, so that's why the baseline of "a bit bigger than Smash 4 but less than base Ultimate" is such a common estimate.