Michigan has more than that, counting their incoming class. Ohio State is pretty close too. Both teams are base 4-3, but will match-up pending personnel.
Including current commitments, we have:
DL (14)
Davis, Davis, Davis, Stoltenberg, Newell, Still, Neal, Natter, Miller, King, Akinmoladun, Thomas, Thomas, Watts.
LB (12 including walk-on)
Alexander, Barry, Ferguson, Gifford, Jefferson, Newby, Simmons, Weber (w/o), Young, Roberts, Hampton, Ward.
Plus, we'd add 2 more DL (we'd actually take 3 more) if it's the right guys and we're only looking at adding 1 LB (Slade-Matautia) and that's it.