User blog comment:X9 The Android/PE Proposal: Zombozo/@comment-4708882-20191014143708/@comment-30757877-20191014144805

The Scarecrow has been portrayed somestimes as PE, like his Nolanverse version or his Arkhamverse version.

And while I know Zombozo doesn't cross the heinous standards as Vilgax and others, for Earth standards he definitely crosses them. Remember MCU villains like Ronan the Accuser, who wasn't as heinous and dangerous like Thanos (planning to wipe out a planet due his radical ideas rather than wipe out the entire universe to recreate it) but still counts as PE...