, 20 or 30 years ago when I was listening to certain engineers and studying this question as closely as I could the consensus was, that a 32 hole wheel was vertically as strong and in some cases stronger than a 36-hole depending on Cross pattern to keep it simple a 32 hole 3 cross is a strong as you can get vertically. If we're talkin the same rim for each example.

​​​​​​ where more spokes make more sense is when you have higher torsional loads side loads and that is where you will notice a performance and endurance enhancement. So if you are the type of rider that spends a lot of time out of saddle honking the bike back and forth... Go with more spokes. If you're gonna pull a trailer a single wheel type especially go with more spokes the more torque you put against the rim can make a difference as well so fat high pressure tire is a larger lever against the rim so aggressive riding would be better served with more spokes in that case too.

this is what they taught us years ago .. if engineering has changed over the years I didn't keep up. But back then we had to wait for our velocity rims from Australia so we had piles of them. And we proved that if somebody really really wants to destroy a wheel they're going to be able to do it no matter what it is.