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ASD steel composite beam design

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Following the examples for composite beam design in the ASD 9th edition, when economizing by taking advantage of partial composite action, does Vh' have to be at minimum 1/4 x Vh?  I ask because for a fully composite beam, I would need a total of 70 weld studs.  But, when computing for partial composite beam action, to economize on the weld studs, the calculated Vh' is a hair above 0kips.  Intuitively, I would guess that the intent of the 1/4 Vh is to have some horiz shear force to design for, although it is not explicitly stated in the spec or commentary...
TIA for any clarification provided.

David A. Topete, S.E.