User blog comment:Sppople/PE Proposal: Ungoliant/@comment-27022982-20200105040213

No because we don't know enough about her origin. She is a GDV as she represents greed and hunger but not much is known about her personality, and there are many theories as to what she is, ranging from a fallen Maiar to the personification of the Discord of Melkor. None of them are confirmed, so we can only guess.