@gsiemens asked about a definitive critique of Open Educational Resources. (as an explanation, he clarified that he was looking for "I want a critique that provides a broader view of OERs beyond "it's all good" What is the impact? The negatives? Who loses?" cf http://twitter.com/gsiemens/status/1477417505)

I am not sure a definitive one exists, but there have been lots of individual criticisms. this is a brain dump of the different arguments I have seen, which I will attempt to fill in with examples as time permits. Please feel free to add to them with the guest account (username: edtechpost_guest, same password) and annotate with URLs exemplifying these arguments.

OER are too content centric: this argument goes something like "OER is all about content, yet education is clearly FAR more than just content"; they represent a continuation of the 'banking' concept of learning (a la Illich)

OER are culturally imperialistic: there's a lot that falls in this category - OER, as dominated so far formally by western Universities, represents the continuation of 'North/South' development efforts; they promote english as the lingua franca of education; they promote a western (content-centric) model of learning; they focus on western technologies and knowledge;
Examples


OER are not effective: whether it be the "just share already" criticism of formal projects, the observations that OER seem to continue institutional and educational silos, critiques of repositories and metadata; critiques about the quality of OER that currently exist; critiques that the 'remix and reuse' that are part of the promise of OER don't match with the reality of the educational process

OER are not open enough: this critique often involves licensing disputes, specifically around the Non-commercial clause as well as the necessity of the Copyleft variants (Share-Alike); could include in thhis license incompatability (or this could be a separate critique)

OER are a marketing ploy: many are suspicious of early OER efforts that seemed big on marketing impact, maybe less so on educational impact

OER are not sustainable: many large-scale OER projects were funded on grant money, soft funding, and were positioned as 'publishing' projects instead of becoming core to the institution's own teaching/content development processes, and thus their long term sustainability seems suspect

OER are just Learning Objects in disguise: this ties into both the "OER are not effective" and "Why OER?" arguments, and many people see the same criticisms that applied to Learning Objects and Learning Objects Repositories as being equally fitting here.

OER aren't getting used:often based on anecdotal evidence, the claim is that OERs are simply not getting used, usually focused on instructors re-use but same is often claimed for students

No-one has heard of OER: cf above, some claim that for a 10 year old movement it is still pretty marginal and unknown

People shouldn't have to give away their valueable learning content?: This, and variantions on it, are not so much critiques of OER as reasons given for not sharing

Why OER? Isn't ANYTHING that's "Open" potentially an "Open Educational Resource" - cf Downes on 'tissue paper as learning resource'. Also cf. @brlamb and others on "with so much open content already around, why worry about OER specifically"
Examples

OER are undermining the publishing industry: might as well throw in some straw men here, don't know if I've ever seen anyone make this argument, and not sure anyone would mind ;-)

OER undermine institutional education: again, seems a bit cartoonish, strawmanish, but I am sure that some people resist it on this ground