Size is not the test. She qualifies if she primarily manages the organization or an essential function with real discretion and personnel authority, and if others perform the operating work. She does not qualify if she is mainly a working supervisor of non-professional staff.
The regulation measures what she decides, not how many she employs
USCIS has repeatedly stated that a small company can support an L-1A petition and equally that a small company's owner or general manager is not automatically a manager in the regulatory sense. The question is whether the position is primarily managerial. The definition covers managing the organization or a department, function or component; supervising the work of other supervisory, professional or managerial employees or managing an essential function; having authority over hiring, firing and personnel actions or functioning at a senior level; and exercising discretion over daily operations.
A general manager who sets strategy, negotiates the lab and export contracts, controls the budget and directs two technicians and a bookkeeper meets those elements, but the file must demonstrate that the technical and clerical work is done by those staff and not by her. Where the technicians are part-time and she does much of the work, the honest answer is that the position is not yet primarily managerial, and the fix is staffing, not drafting.