It really depends on your specific conditions. I need to protect chestnuts in my area. We have lots of native persimmons. I haven't had issues with deer bothering persimmon seedlings. I know others have had issues with deer and persimmons and do require protection. Of the two, I'll worry more about chestnuts in general. I tried the "Overwhelm them with numbers" approach and it did not work for me. I had to go back and add protection.