Here's a hint: any time someone says "X can *never* be fair use," they are wrong and don't know what they're talking about (same goes for "X is *always* fair use"). Likewise, anyone who says, "Fair use is assessed solely by considering the 'four factors.'" That is your iron-clad sign that the speaker does not understand fair use:
https://pluralistic.net/2024/06/27/nuke-first/#ask-questions-never
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