NYT v Sullivan is only relevant to public officials - those holding or running for public office, which adds for them the requirement to prove 'actual malice.' In subsequent cases, the requirement has been expanded to employees of public officials as well as public figures - those who "achieve persistent fame and notoriety" and those who voluntarily engage in public controversy. In either case, the owners of a small company who have not voluntarily placed themselves in the public eye would be generally considered private individuals and thus the restriction on suing the media for defamation would not apply.

In lower courts there has developed some concept of an involuntary public figure. These are people who don't go out of their way to enter the public spotlight but who are involved in an event of overriding societal importance. So for example people being investigated by a government agency major crimes can't sue for defamation after being found not guilty. If JetBrains is actually under investigation then it's fair game, but if not it likely is still a private figure and this would be a pretty good example of a valid defamation case.