That's true. But since it's taking the same setting, places, stories & characters, I'm pretty sure it's fair to say 'based on'. All changed to more or less deg

That's true. But since it's taking the same setting, places, stories & characters, I'm pretty sure it's fair to say 'based on'. All changed to more or less degrees like all adaptations. I guess they're skirting the rights issue by never actually (that I noticed) mentioning the Silmarils. YMMV.