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Against a weaker foe, having numbers is beneficial, but against trained opponents, zako tend to go down quickly in the dozens.

I'd figure Poison Ivy would hire girls based on their devotion to her cause rather than looks or toughness, where as other villains would hire for the former. Penguin probably hired his henchgirls off of looks in this case.

(Don't have any pictures, but I quite like Zakoholic's comic with Jay Raven and Lark having a bunch of new recruits fight Batgirl)