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"substantive criticism" is a correct and usable phrase in written English.
It can be used to refer to thoughtful and constructive criticism that is offered with the intention of improvement. For example, "The student received substantive criticism from the professor about her presentation, but afterwards she was able to make the necessary changes to improve her grade."
Exact(40)
We investigated whether authors responded adequately to substantive criticism after publication and whether the critics and the editors were satisfied with the replies.
This is a far more substantive criticism than the debate over the precise numbers above.
It is not that they object to "substantive criticism," they later insisted.
Republicans had their substantive criticism of the Democratic bills, but Obama kept pressing them for areas of agreement.
Still others said their opponents spent so much time deflecting questions about scandals, they never had to face more substantive criticism.
But the more substantive criticism is that it has a scattershot approach to economic policy, with little regard for the nature of markets.
Similar(20)
Both sides scream "lock 'em up" instead of making substantive criticisms of opposing views.
So it seems to me that the more substantive criticisms of this is that you are asking government to do a lot of new things.
And thus far he's done better than expected at threading the needle between supporting Trump and not recanting the substantive criticisms he leveled during their primary contest.
But the White House instead smeared Clarke personally, ignored his substantive criticisms and, in the process, helped turn Sept. 11 into a political football.
Whatever the substantive criticisms about Mr. Obama's trip, it is ironic that he is also being faulted for the cost, which the Washington Post reported was in the range of $60 million to $100 million.
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Since I tried Ludwig back in 2017, I have been constantly using it in both editing and translation. Ever since, I suggest it to my translators at ProSciEditing.

Justyna Jupowicz-Kozak
CEO of Professional Science Editing for Scientists @ prosciediting.com