Deuterium fusion mass limit

The Deuterium-Burning Mass Limit for Brown Dwarfs and Giant Planets is dependent on metallicity and initial helium and deuterium abundances, and can range from about 11 to 16.3 Jupiter masses. If you favour the deuterium fusion criterion for distinguishing between planets and brown dwarfs (personally I don't), this makes things more complicated.

If I recall, you favour the formation method criterion.

Can core accretion create planetary bodies above the deuterium fusion limit? (and can disk instability produce objects below the deuterium fusion limit?)

I'm curious if there's a bit of an overlap for the formation method criterion as well.

I think there is.

Plus:
Core Accretion - 2 bodies merge that throws it over the limit.
Disk Instability - 1 ciphens from another preventing from accreting enough mass.

Possible?