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"No comment" indeed contradicts nothing. Unless of course there is other pronouncements, statements or actions which say otherwise.
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"No comment" contradicts nothing, including other comments. It's just a way of saying "whatever I may think, I'm not telling you." As a lawyer, my telling a reporter "no comment' doesn't mean I have no opinion about the case!
If your spouse/significant other puts on what you deem to be an absolutely hideous outfit, it's not 'contradictory or two-faced' to keep your mouth shut and avoid a night on the sofa.
"No comment" certainly isn't some sort of declaration along the lines of "I promise not to form a personal opinion about the movies when they come out."
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I do think it is less than honest for someone to take one position on an issue where they maintain the high road due to their official capacity in an organization and then take a far different position and claim it is only the feelings of a single individual and means nothing.
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Your argument would have force only if the Estate/Tolkien family had done some such thing. In fact, their personal and private opinions have remained private. Moreover, you again assert that there are 'far different' positions involved here: which is, in your phrase, comparing apples to cinderblocks when one 'position' is mere silence. Nothing in CRT's public statements declares or implies "I'm completely indifferent." Just "I'm not talking."