The devil's in the details, one Gateway can communicate with up to 10 Powerwalls. But that's not the same as handling the load of 10 Powerwalls.
Technically, we could upgrade to a single 400 A load center, hook up 10 Powerwalls there (avoid Gateway altogether), and then only have a 200A connection to the Gateway and home loads. This could work because the home would never pull more than 200A anyway from the Solar and Powerwalls. This doesn't take into account grid charging though and no idea how we could avoid pulling 300A through a 200A service if all 10 Powerwalls are drained and trying to charge.
All that seems expensive so I think that's why Tesla would add another load center (second Gateway?) that consolidates 3-4 PWs by themselves and distributes power to the home. Everywhere I see more than 5 PW's installed people end up with two systems on their Tesla App.