The Penguin resurfaces during Jean Paul Valley's tenure as Batman and is one of the few people to deduce that Valley is not the original Caped Crusader. To confirm his theory, he kidnaps Sarah Essen Gordon, places her in a death trap set to go off at midnight, and turns himself in, utilizing the opportunity to mock her husband Commissioner Gordon as midnight approaches. An increasingly infuriated Gordon is nearly driven to throw him off the police headquarters roof before Valley rescues Sarah moments before midnight. As Valley leaves, he says, "There's nothing the Penguin can throw at me that I haven't encountered before." The Penguin reluctantly agrees with this sentiment, accepting that he has become passé. Subsequently, the Penguin turns his attentions to a new "modus operandi", operating behind the front of a legitimate restaurant and casino he calls "The Iceberg Lounge", which Batman sometimes uses as a source of criminal underworld information. Though he is arrested for criminal activities several times during the course of his "reform", he always manages to secure a release from prison thanks to his high-priced lawyers.