User blog comment:Sppople/PE Proposal: Ungoliant/@comment-29644557-20200104223609

I guess it depends if she had the same resources at her disposal as Sauron and Morgoth. If so, then no, she doesn't meet their heinous standard. If not and she has considerably less power, time, or resources to work with and still manages to commit the atrocities, then yes, she would have been using her limited resources to reach a level near to or on par with the aforementioned villains.