I would always make a starter when using liquid yeast regardless of the OG. The viability of the yeast can vary depending on the production date, whether it travelled to you during warm weather (if ordered through the mail), and other factors. Therefore, it is always safer to make a starter. In some cases, you may find it easier to pitch more vials or smack packs, but you still may not get complete attenuation. For example, I pitched 3 vials for one of my brews and I still ended with a stuck fermentation. In hindsight, I should of made that starter..