Um...No.
TDK still stands today as one of, if not, the best CBM made to date. The argument of 'if it were made today' is irrelevant...TDK has inspired a whole new breed of CBM films and elevated the genre to a new high point much like SM2 did back in '04.
I also really hate and find disgusting this whole 'Marvel v DC' crap. Why is it so difficult for some people to understand that bad films are just that, bad films? Critics are not going out of their way to bash this movie 'cause it ain't Marvel.' That's ridiculous and it's ridiculous to conclude that the only reason it's not getting good reviews is because of some hidden agenda. If you love this movie, more power to you, but don't slam people for having a differing opinion and try and make up reservations to justify why they don't like it.
I see plenty of Bat/Supes fans condemning this film as much as I see others. AND...more importantly, they have good reasons for doing so.