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A movie doesn't need to be packed with non-stop action for it to be an action film. Collateral had a lot of scenes that constituted its status as an action film although that's not to say there wasn't some drama. As for Punisher, it was simply a poorly done action movie.
Whenever action is used as such a huge plot device, that movie can at least linger in the genre if somebody wants to classify it as such. Kill Bill Vol. 2 is simply the second half of a larger film and Kill Bill is an action movie.
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