I will say it is not defamatory to make the factual statement you hired someone and got bad service, no batter what the business thinks.
If you are making a factual statement - and I interpret that to mean a statement of fact that is actually the truth - then by all means. In this case, the business believes that the statement is not the truth, and further believes it has damaged their business.
Whether or not that is actually the case (either way), let the courts decide.
In this particular case, the business owner believes
Bullshit. Do you have facts to support this? Or are you just asserting it?
Do I have facts to support that the business believes something? No. I can't read their minds, and neither can you.
So can I say with certainty that the business actually believes in what they write in the allegations - e.g.:
5. The entire review is false as it pertains to the plaintiff.
6. The review as published by defendant DOE 1 is libelous on its face
- no, I can't say with certainty that they actually believe this, and aren't just using these and other allegations to try to silence critics. The suit is the evidence before me on which I base the description that they believe it. If you want to split hairs and suggest that I should have said that these are the allegations, fair enough.
If those people actually did hire this company, and if they are giving actual negative reviews, this lawsuit is nothing but intimidation tactics by assholes.
That's two ifs that would end up being at the core of either this or follow-up lawsuits, now wouldn't it?
If those people are actually just 1 person and if their reviews are anything but honest, then this lawsuit is well-founded, the reviewer is nothing but an asshole, and additionally in legal trouble?
How do we find out which of those scenarios apply?