I don't think so - it depends in the individual case. You could class Valve as a moderately sized independent - they release one game per year ish, but they seem to be doing okay. The examples cited in the article are companies who put all their eggs in one basket with Lair and Haze respectively - two games that simply weren't very well received at all by consumers or press. I think developers releasing badly received games would be under pressure whether it was a recession or not.
Not really good examples. Those devs really, as Alex said, bet on a shitty game. Yea, obviously the recession is affecting them, but it's not really to medium sized devs.
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