Those That Can't Do, Troll

Righhaven tracks internet traffic to search out copyright infringement. In this case, bought rights so they could have proper standing to sue political candidate Sharron Angle. So why doesn't this fall under the fair use exception? Elements for analyzing fair use include purpose of the use, nature of the work, the amount used compared to the amount copyrighted, and the affect on the copyrighted market. It must be that in this case, a political candidate's use of news articles is closer to commercial than non-profit use because she is campaigning for the political seat.