OvershadowedByControversy: Does it have to involve 2+ large, vocal factions?

I'm confused by it, because Overshadowed by Controversy refers to a work that is lesser known than the heated debate about one of it's subjects. Does the "heated debate" part have to have two (or more) vocal, large factions? Or can it be where there's only one large faction, overpowering the significantly smaller ones? The latter can have the existing examples segerated into Overshadowed By Heresy.

I don't think that the size of the groups involved has anything to do with it. All that needs to happen is that this controversy gets in the way of people enjoying or discussing a work.