Yes, I do think so.
It's not as stupid as The Voyage Home, Generations or AbramsStarWars, not as messy and silly as Insurrection, not as amateurish as TFF, not as boring as TMP and TSFS, but it doesn't approach the quality of First Contact, The Undiscovered Country or even (and I'm going to get doused in gasoline for daring these words*) Nemesis.
I just don't get this movie's appeal:
- the creatures manipulating Chekov&that other guy are such a cliché. And frankly, one too gory for Trek (same two reasons I hated "TNG: Conspiracy").
- as someone alluded to, Khan's "genius" is oft-mentionned by never displayed. In fact, he seems a simpleton all things considered. He's all bravado, no brains from what we see. The whole "Khan is smarter, but Kirk is more experienced/more in control of his emotions" theme is rather ruined by that element.
- Khan's last words are brilliant, but they're from Moby Dick...
- Visually, the final confrontation is pretty bad, and I don't mean the effects (they've not aged that bad, especially compared to TFF). The whole thing about the Enterprise moving vertically as if a submarine doesn't make sense on any level.
*then again, not liking AbramsStarWars probably qualify me for the kerosene already. Oh, well, the fire god taketh and the fire god taketh.