As they said the splat then you could replicate those :) I was reading though can't find the post where some of Howiefarkes have over 1,000,000 trees in them.  http://howiefarkes.cgsociety.org/gallery/559385/  he talks about running into the then version of carrara limit of 10,000 per instance and he had over 100 of them.  I am not sure if that is still the limit or not.