I think in 2009 she was still the IT Girl, the shocking girl etc.
While in 2010 people were like. . . Ok. This girl is something else, she is something more.
Now it's easy to say she became an icon in 2009 but back then I don't think many would've considered her an Icon, while in 2010, there was no doubt.
An icon has sustained success and multiple classic hits over many years that have defined and changed music. Germanotta has been doing generic EDM for 5 years and has yet to be proven more than just a passing fad.
i·con
ˈīˌkän/Submit
noun
noun: icon; plural noun: icons; noun: ikon; plural noun: ikons
1.
a painting of Jesus Christ or another holy figure, typically in a traditional style on wood, venerated and used as an aid to devotion in the Byzantine and other Eastern Churches.
synonyms: image, idol, portrait, picture, representation, likeness, symbol, sign; More
2.
a person or thing regarded as a representative symbol of something.
"this iron-jawed icon of American manhood"
Based on the definition of the word ICON i can't say she is one as for now.