The Penguin made his last appearance during the last appearance of the Earth-One Batman. After he and a multitude of Batman's enemies are broken out of Arkham Asylum and Gotham State Penitentiary by Ra's al Ghul, the Penguin carries out Ra's' plans to kidnap Batman's friends and allies. The Penguin, along with the Joker, the Mad Hatter, the Cavalier, Deadshot and Killer Moth, lay siege to Gotham City Police Headquarters, but are infuriated when the Joker sabotages their attempt at holding Commissioner James Gordon for ransom. A standoff ensues, with the Joker on one side and the Penguin and the Mad Hatter on the other. The Joker quickly subdues both with a burst of laughing gas from one of his many gadgets.