You could argue that CAMPBELL, AKA SKYYWALKER, ET AL. V. ACUFFROSE MUSIC, INC. [1] wasn't a criticism, comment, news reporting, teaching, scholarship, or research (the court ruled that it was a parody). In CAMPBELL V. ACUFFROSE, the court also ruled that it being a commercial recording didn't stop it from being covered under fair use. There was another case which slips my mind at the moment that found similarly (that commercial use doesn't stop it from being fair use).

IANAL, and I am not familiar with all of the little details that go into determining whether something is fair use. From the reading of the applicable laws and precedents and having an actual lawyer go through those with me (I took a class last semester on IP law), however, I don't see anything that would outright bar this from being fair use.

[1]: http://caselaw.lp.findlaw.com/scripts/getcase.pl?navby=searc...