The limit is in LBM for a given height, not in leanness.
At 5'9 with ~170 lbs of LBM I can be 220 at 23%, 212 at 20%, 189 at 10%, or 179 at 5%.
That's about the limit of LBM for my height (give or take 5-10 lbs maybe) w/o using anabolics.
Pay attention to the bold, it's very important.
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