https://www.anandtech.com/show/16026/tsmc-teases-12-high-3d-stacked-silicon The technology AMD uses to 3D stack L3, SOIC, has been shown to support 12-hi stacks since 2019 with test chips. It shouldn't come as a surprise that AMD's got the ability in 2025/2026 to go above 1-hi layers
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There must be some cost to validate > 1 layer of V-Cache, and past sales of V-Cache CPUs probably did not justify the investment to turn it into a product.
Fast forward from 2022 to 2025 level sales of V-Cache processors, underlying assumptions have changed. Best gaming CPUs are now synonymous with V-Cache and sell in high numbers.
In addition to high profit margins, V-Cache CPUs are a free advertisement for AMD. A brand building product. Now, that Intel is going to be releasing bLLC, I think Lisa will want to smack it down really hard.
Additional layer would do just that, but it would do even more. It would show AMD's technological superiority, showing that AMD can just slap an extra layer while Itel has to redesign the entire CPU chiplet every time Intel wants to give it more L3.