I kind of agree.
I don't think its a great comic book movie trilogy because it captures very little of the comic book essence or aspects of the character or concepts of Batman.
Its more based/forced on "Realism" than the "Fantastic" nature of comics, which is not a bad thing, just a specific taste. But Bale's Batman captures very little of what Batman really is. Baleman is not a detective, at all. He's not very smart or aware (he falls into traps and gets outsmarted in every movie), He isn't a fierce fighter or a crafty strategist, he gives up protecting Gotham to go pal around with a girl he barely knows, he relies a lot on the assistance of others rather than being the guy to take the burden on himself... As I'm typing this, I'm realizing a lot of my issues were much more prevalent in TDKR than TDK but the seeds and aspects were present in that movie. I'm not saying its a bad movie at all, its actually a spectacular thriller/adventure movie, just not the best comic book movie to me.