it depends on how one defines "primitive". If one is purely going by the phylogenetic and evolutionary scale, then it is reasonable to correlate # of offspring/progeny with eukaryotic "complexity".
However, one must be wary of terms like the such because they are biased from a human (mammalian) pespective.
On the other side, one could argue that # of progeny is not a defiitive marker of the eukaryotic complexity scale, but rather merely an adaptation to environmental stressors.
For example, the human, typically gives birth to 2.3 offspring ( a function of the number of mammary glands!), however, creatures not bound by a function of the # of mammary glands or those that face a different environmental stressor by way of predation more than likely will give birth to or yield more offspring to account for the environmental stress. This does not mean in a biological sense for ex that humans are "less primitive" than oak trees.
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