It’s probably not a bad game if taken out of context and enjoyed without prejudice. I even remember some moments when the bullet action triggered some Max Payne flashbacks, but they were relatively rare. It also has some stupid scripted sequences that start with Max pinned down behind cover, which kind of create the opposite of Max Payne feeling for me, but those aren’t too frequent either.
It’s just, Max Payne 1 and 2 were carried strongly by their film noir atmosphere, which is completely absent in 3. In 1 and 2 it all somehow fitted together, the gameplay, the strange mix of taking itself not too seriously, yet still telling quite a dark tale, the city being hit by a winter storm, events narrated by a monotonic voice in prose that borders on the poetic…it was just all somehow a complete and specific experience.
And 3 is just different. It might even do something similar for different people, it just didn’t do it for me.