Originally Posted by Clerk
Yeah, if you watch the Batman Returns special features, I believe even Tim Burton says that WB wanted him to use Penguin because the character was the "number two guy."
Yep, it was always Joker first, Penguin second up until 1992. Two-Face wasn't nearly as well known outside the comic community until the early 90's even though he's been considered the number two foe in comic circles for decades. It would have been a different story had he been in the 60's TV show, but he was deemed to grusome a character for the tone of the series. The animated series is really where he was brought back to life and like it or not Batman Forever was what finally lifted him to A-list status for the general public. Dent is now a solid number 2 in the rogues gallery and will be for the foreseeable future thanks to Nolan.