For me it always felt like a deliberate riff on TDK for the reasons you state: It blatantly starts off using the same themes and concepts, including the constant media interruptions. But it's where it goes from there that's interesting. It's sort of a "What If TDK was about Spider-man not Batman" and rather than changing Spidey's character to be Batman, it clearly highlights why he's NOT Batman by the end of the book.