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I think 20L mATX/ATX (with 7 slots) is somewhat reasonable. For ITX, I'd say 10-15L if you want watercooling and an internal PSU, but if you're okay with small coolers, risers, and possibly power bricks, 10L becomes more of a maximum. Of course, you can always make a case much smaller - there exist STX cases under 2L so the sky's the limit!