I think you misunderstand me or I didn't put it clearly enough. The key concept is sometimes... occasionally... if you are willing to make a big fuss and the hotel has been lazy in preparing its list of "resort fee benefits".

That said, way before COVID, the Westin in Vegas for example used to waive part of the resort fee for elites who mentioned it. IIRC that hotel-level policy went away roughly around the time of the Marriott merger. But resort fees are such a part of Vegas that is probably the last place I'd expect to have much success arguing about it.