User blog comment:Scottish-Terror/Pure Evil Proposal: Magistrate/@comment-2059440-20190511030428

unfortunately in the Marvel multiverse one murder, no matter how tragic, is not enough for PE - even if you say this is one story it is actually connected to a larger arc.. where Hulk is doomed to travel the Crossroads - he faces many other enemies and Zgorian's bones are seen to shake when his fight with the U-Foes echoed across dimensions, confirming the story was not self-contained but part of a larger canon.

that makes it much harder to have this character be a contender - if he was from Pre-FF era he may of had a better chance as that was before Marvel had a shared canon.