This is my attempt. (All of the stones must be solidly connected, else pieces can be cut off given infinite white moves.) -- Blake
How about something like this:
A couple freebies, I think:
45 stones are not bad, but there is still a lot of room for improvement!
LukeNine45: Not an improvement, but it looks nicer! :)
2 eyes just weren't enough :-) --Bass
An "obvious" enhancement. --Bass
Shape seems to be the key here.
Small improvement.
Yes, the shape you used is indeed vastly better. Here's my go at it. --Bass
ferdi: The following try isn't in the running because changing the conditions doesn't count as solution ;-)
If you allow positions where every stone in the group is necessary and the group cannot be reinforced further, but you omit the infinite white moves rule, then seki is possible:
(Most 2-group sekis do not fulfill this requirement, because one or more stones could be removed and they would still be seki.)
Eric Boesch?