Earlier quoted context omitted.
I think the biggest case for fine tuning is probably that you can take small models, fine tune them for applications that require structured output, and then run cheap inference at scale. "Frontier LLMs can do it with enough context" is not really a strong argument against fine-tuning, because they're expensive to run.
I agree- I'm currently trying to learn how I can embed a fine tuned tiny model into my c++ game so it can provide a narrative in prose of certain game-event logs. It needs to be as tiny as possible so it doesn't take resources away from the running game.
Unless your game states have combinatoral exlosion, would it not be better to generate all of that pre-build? If templated you can generate a few hundreds of thousands of templates to use for any circumstance, then instantiate and stitch together those templates during the game runtime.