Sounds very similar to the Shadow of Mordor concept, it's definitely a decent milieu to drop into.
I think it's likely to feel rather bad and ungainly though, as it'll be aesthetically indebted to the Jackson films but won't have their great level of detail in its production design or, you know, the original Tolkien material to work with.
Fully expect stupid character names and situations that don't feel like Tolkien, just as they were already veering into with the Hobbit flicks (the ridiculous sled that Radagast gets around on and so on).