Without Xmas in the movie, then it is not a Xmas movie. So no to Shazam being a Xmas movie.
And if Die Hard is a Xmas movie, then so is Money Train.
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Santa Claus: The Movie is that bad, huh? 
Joking aside, I totally get your perspective. The very best Christmas stories often are about the holiday itself, so it checks out.
Also TBF, I see Batman Returns as being more a great Halloween movie than a Christmas movie 
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Off-topic, but Scrooged has a great ending. Just the right kind of 80’s wholesome!
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Batman Returns in not Halloween. It is however a great election day movie.
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Not quite for me
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Same with Batman Returns, I’m going to say yes. 
SHAZAM! 
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Yeah but election day is in November, this is now late December as The Penguin notes soooooo…lol
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Christmas decorations are up in November
Festivus, haha, nice!
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Hence, a War on Thanksgiving!
Yes, it’s a Christmas movie for sure.
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Why’s that?
It’s set at Christmas and we see various characters do Christmas stuff, like the parents setting up a tree.
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It’s an age-old debate, but I would agree it’s a movie I watch specifically around Christmas given the setting.
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But it could have happened at any time of the year
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Putting up a Christmas tree, Christmas decorations everywhere? No, this was Christmas.
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Hapy Holidays Too the Entire D.C. Community! Happy New Years D.C. Community!
I Think Shazam, is A Christmas Movie!
Very Colorful and Festive!
I would have to say a hard no to Shazam being a Christmas movie, even though the movie enters into Christmas, because the standard at least for me, is Die Hard.
Die Hard takes place square smack dab in the heart of the Christmas season with a big part of the plot being John Mcclane traveling to L.A California, not on business, but to see his newly separated wife or about to be, forget which it is , at a Christmas party, he was attending to family matters and to be with his children on Christmas, the action was just an event that happened to take place.
Where as Shazam, is about a boy looking for his biological mom, and it happens to be winter, and approaching the holidays, and happens to become a superhero on top of a bunch of other issues, that all coincidentally are running into Christmas.
Pizza
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In Die Hard they are about to separate. They are still married. Hence the badly explained synopsis- A guy goes to his wife’s worst office Christmas party ever.