Yes, but yeast growth in beer can have flavor consequences.
The maximum cell density for 19 liters of wort is 3.8 trillion cells; hence, the difference between 100B cells and 200B cells is insignificant. In fact, the difference between 100B cells and 400B cells is insignificant unless one is dealing with the cell destroying effects of high osmotic pressure.
What's more important when pitching a starter is the health/state of the cells. Cells that are pitched at high krausen are still in the exponential stage, which means that have ergosterol and unsaturated fatty acid reserves that only need to be topped off. Cells that have reached quiescence have undo the cell wall thickening that occurs at the end of fermentation. They also have to rebuild the ergosterol and unsaturated fatty acid reserves that were wasted producing replacement cells after the exponential phase was exited.
log(3,800 / 400) / log(2) = 4 replication periods (rounded up)
og(3,800 / 200) / log(2) = 5 replication periods (rounded up)
log(3,800 / 100) / log(2) = 6 replication periods (rounded up)