Put it this way:
There are great Batman villains: Joker, Two-Face, Ra's Al Ghul, etc.
There are middling Batman villains: Clayface, Mr. Freeze, Poison Ivy, etc.
And then there are just plain sad Batman villains: Calender Man, for example.
Now, here's the thing: the Penguin definitely falls into the just plain sad category. BUT, he also works in Gotham. That automatically places him a cut above villains of the same level in other cities as far as being lethal goes. Gotham is such a crime infested despot that ANY criminal who can survive there AND work as a crime boss there has more.. eh... huevo's... than any criminal on the same scale from another city is outmatched. Hell, three or four low level criminals tried to come in and strike a deal with Penguin. Penguin nearly trapped them to death, stole their cash. Only reason they survived was because Batman showed up and pretty much said, "You're in Gotham. You're out of your league."
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