Considering film noir was a retrospective label applied to these films in the 1950s and 1960s, rather than a label that was in the minds of the filmmakers when they made them, it's hard to pin down the exact characteristics of films noirs. For some people, Citizen Kane is a film noir; for others, it isn't, even though it shares many of the characteristics of the noir pictures.
Most of the makers of what later came to be called films noirs, considered their films to be melodramas. In that sense, Ace in the Hole fits the bill perfectly: it's a melodrama with a very bleak outlook on human behaviour. Films noirs don't have to deal exclusively with crime or detectives - that's a very reductive definition of the film noir type (I hesitate to say 'genre', because noir arguably isn't a genre) of the kind that you find in lazy journalism - they simply offer a view of the darker side of humanity (greed, exploitation, etc), often with the use of visual techniques derived from both German Expressionism and the documentary-like techniques and perspective associated with Neo-Realism.
'What does it matter what you say about people?'
Touch of Evil (Orson Welles, 1958).
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