I think it can mean a lot of things like
the dev being partially owned by a company like Sucker Punch used to be owned by Sony until fully bought out
or a dev who only works on a company's IP, like insomniac was before Sunset Overdrive or Quantic Dream now
and then there are 2nd party games from 3rd party devs, which I think ranges from exclusive deals (Titanfall), owned IP (Quantum Break), co-developed games (Bloodborne) etc.
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