There were many moments I found laugh out loud funny, and I think they were supposed to be - from the bickering one-upmanship of the stage door fans, to Rupert's frustrated shouting upstairs to his ma, to the cue-cards scene (Rupert's "disguise", his facial expression, and the bored, bemused demeanour of Langford as he tries to direct Rupert with the cards)...there's a broad streak of comedy running through this.
I don't think it ever claimed to be a "comedy", despite the title. It's just a great movie, and a lot of great movies have comedy sprinkled over them - Citizen Kane, The Godfather, Taxi Driver - bleak humour, cruel humour maybe, but humour nonetheless.
Just about every scene with Rupert is extremely funny, because in every scene, the mismatch between reality as it is and reality as it's perceived by Rupert is so extreme and absurd. Rupert's interactions with the staff at the studio are particularly hilarious, these are the best scenes as far as contrasting Rupert's deluded and inflated self-opinion versus the way the rest of the world sees Rupert.
I think the seductive dinner scene with Sandra Bernhardt is the only truly funny part that I remember, and her running after him naked. I think her final line that she shouts down the street after him is a gag-type line, if I recall correctly, but even that scene is AGONIZING to watch. It's horrible-funny.
"It's as if God created the Devil...and gave him...JAWS"
To me it was pure comedy. But I even think Happiness by Todd Solondz is hilariously funny (and disturbing at the same time). I guess it depends on your sense of humour. I know people who couldn't bear to watch Happiness for more than 20 minutes.
I think one of the points to the movie is to keep the audience wondering if this guy is a total mental case, or if he actually has something.
Now when we finally see him do his act in the end, he's not extremely funny. But he does the job pretty good. So you kind of feel happy for him getting some recognition.
But I see the movie as a metaphore for all people with some sort of talent who think there is a shortcut to fame. Everyone from those who sings on American Idol, to those handing tapes to celebrities thinking they will make you as famous as themselves. It's more tragic than funny.
On the one hand, Rupert is a pathetic character, but his embarrassing behavior in public and his complete lack of self-awareness are comical.
Similarly, the broader theme of the satire - society's obsession with fame, and the rise of "famous for being famous" celebrities, is a tragic sign of cultural decline, but that doesn't mean that it can't be effectively poked fun at and used for laughs.
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There are some very funny scenes, like when Rupert tries to record and his Mum constantly interrupts, some scenes with Marsha are also really funny. But on the whole it is very dark humour that also has a very tragic streak to it. Especially when Rupert does his stand up routine and all these jokes he brings are actually very tragic stuff that happened to him IRL.