Originally Posted by Stormwaltz 
Don't we already have our film noir developers? Jeff Vogel, Bay 12's Dwarf Fortress, the recklessly original hybrid games coming out of Eastern Europe, Matrix Games and Battlefront.com…
I think the issue is that those games do not function as a part of the industry, they work outside of it. They're like independent films, while film noir as a sub-genre was not a part of independent filmmaking.