Jean Kilbourne claimed fair use in Sut Jhally's Killing Us Softly when she quoted advertisements for her argument that women's body-image expectations are shaped by popular culture. Kilbourne and Jhally were able to claim fair use because she was criticizing the pieces of media that she showed to viewers.
In Outfoxed, Robert Greenwald employed fair use with the material he quoted from Fox News. Greenwald considered these quotes fair use because they were directly related to his critique of Fox News' ideological bias. Other filmmakers agree.