Dominion seems to be very clearly a “Limited Purpose Public Figure” in the domain in which the disputed statements apply.
Their lack of general celebrity is a good argument that they aren’t an “all purpose” public figure.
Well, it's not that strange, if you look at how frequently mere threats of defamation lawsuits are used to chill free speech.
But the defamer in this case is the President of the United States and his legal team. That sort of falls down.
I wouldn't call it unfortunate. If you don't want to be a public figure, one thing of which to steer clear is certainly the business of operating voting systems in the US presidential election. This is clearly public interest.
The Covenant Kid was thrust into the media and when he sued for defamation, at least some judges accepted the claim that he was a public figure — even though he was suing over the very thing that thrust him into the national spotlight.
Obama was a public official, so the standards for public figures that aren’t public officials wouldn’t apply.