Take a few minutes to poke around TechRights Garrett pages. This easily would have cleared the per se threshold in the US, too, although the damages assessment would not have been as straightforward.
Except that the "Opinion" defense in this judgement is fussier than US law (in US law, opinion is flat-out protected, honest or otherwise, so long as it doesn't directly claim to be based on undisclosed false facts), this reads pretty similar to a US libel case. I get that the two countries have very different legal doctrines on defamation, but they don't seem to be on display here.
Also: a US judge would have been a lot less nice to the defendants.
