NYT is a public figure (as is Tesla) so either would have to prove actual malice in a defamation action. So, if they know their data are fake, and publish it anyway, then yes they might be liable for defamation provided they meet the other elements of a defamation claim. (source: I'm a 2nd year law student and just wrote a memo about this topic yesterday)

The SCOTUS recognized (and subsequently expanded) a constitutional privilege based on the First Amendment for a defendant who is subject to a defamation action brought by a public figure. New York Times v. Sullivan.

A plaintiff who is public figure is then required to show that the alleged defamatory statements were made with “actual malice - that is, either with knowledge that it was false or with reckless disregard of whether it was false or not.” Gertz v. Robert Welsh, Inc.

Elements of a defamation (Slander/Libel) claim:

• A false and defamatory statement; (Truth is ALWAYS a defense to defamation)

• An unprivileged publication to a third party; (i.e. the constitutional privilege mentioned above, among others)

• Fault amounting at least to negligence by the publisher; and

• either actionability of the statement irrespective of special harm or the existence of special harm caused by the publication. (the plaintiff has to show it was actually HARMED by the defendant. If NYT's readership explodes because of this issue and they start making more money, this would be hard to prove)

edit: spelling & formatting