It is probably the case (but not guaranteed) that a court would read "makes any claim" a bit more narrowly to mean only legal claims, not blog posts. It's a common phrase used in e.g. statutes as a term of art, and usually taken as narrower than a phrase like "expresses a view". However it would almost certainly still include USPTO administrative challenges (e.g. challenging a patent by demonstrating prior art), which is still a big problem.