Making 'indie' video games gets trickier as industry evolves

According to the article what is trickier is not making the games, but being "successful" and get profit from doing it, but that is because of how games are clasiffied as "indie" now, if a studio with two dozen people spends millions of dollars to make a game is included obviously the game has to be very profitable in order to be a success. 

Studios that are just 3 people making a game in their home computers do not have that high threshold to reach so there is nothing specially tricky about the process.