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No, not really. How do you envision that? Maybe mount the PSU across the front as standard, so the case can be made shallower - say 280mm, so we can keep reference GPU support at least. Then drop the third slot, bringing the height down to 220mm. That gives you 220x160x280mm, or 9.9L. I guess you could go all the way down to 250mm or so on the depth by limiting it to short GPUs, putting you at 8.8L. I think the proportions start to look not so great, though. I think my preference for sub-10L is to use risers to enable a slimmer design.
