I think four top guys (plus one sub, female or male), if only to differentiate from an orgy which would have to consist of 3 + 1 in order to differentiate from a threesome.
A note on orgies, while we're here: I've seen far too many videos billed as "orgies" where it's really just two couples keeping to themselves. All four (minimum) MUST participate as a group, or at the very least switch at some point (lame orgy) in order to qualify.
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