Correct, you need one of the ZIS-3 batteries with at least as many guns before you get the bigger ones. Pretty standard across all the lists with the exception of the Germans.
However, I think out of FE2 you can get one of the "smaller" batteries with 4 122mm rather than the 4/8 ZIS-3.
Personally, I think I would go with the ZIS-3 though with the increases range and rate of direct fire plus the higher AT. Its a bit more tectically flexible.
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