Only time I have been tempted to ask someone to be more quiet was when a couple were watching the movie with headphones and were shouting comments to each other about what was on the screen. I didn't though. These particular folks struck me as being of the sort who would not have taken even the most polite request well at all.
Personally, I find loud talkers to be quite rude or perhaps merely oblivious. Which ever, they are very annoying. In any situation which brings many people into close quarters, IMO it is simple manners to modulate one's voice so that those around are not forced to overhear everything that is said when they have no escape.
Talking loudly as intentional punishment for someone reclining is childish and spiteful, IMO. Me First, Princess?