Counter-based broadcasting improves the performance of flooding by preventing the network from being swamped by a large number of rebroadcast messages. In such approach, the rebroadcast decision is made based on counting duplicated packets in order to restrict the number of extra retransmissions. In this article, using a rigorous theoretic analysis, an upper bound on the performance of counter-based broadcasting for saturated networks is derived. Our model assumes a CSMA-based static multi-hop ad-hoc network. The derived analytical model can be used to predict the behavior of counter-based broadcasting schemes. It especially provides the required insight on the impact of different network parameters on the overall system performance. Simulation results are also provided to validate the proposed models and demonstrate the tightness of the achieved upper bound.