The fourth episode of Marvel Studios' She-Hulk: Attorney at Law brings on Disney+ things full circle for the character, as the heroine faces a copyright dispute regarding her name - a dispute that has its origins in a real-life concern Marvel Comics co-founder Stan Lee had back in the character's early days.

Spoilers ahead for August 8's She-Hulk: Attorney at Law, season 1 episode 4.

She-Hulk served

It was another busy week for Jennifer Walters, who helped Wong win a cease and desist case against an amateur sorcerer named Donny Blaze (no relation to Ghost Rider). Jen also tried her hand at online dating, with mixed results. However, the end of the episode showed us that her troubles are only beginning, as Jen was visited by a process server.

It seems that the influencer turned villain Titania is suing Jen for copyright infringement over the name She-Hulk. Titania apparently registered a trademark on the name She-Hulk, most likely as a way to get back at the gamma-radiated lawyer. This forces Jen into fighting for a name that she was never thrilled to have in the first place.

The Marvel Cinematic Universe version of Titania was first seen in She-Hulk’s Disney+ premiere episode. The short-tempered social media influencer attacked a courtroom before Jen transformed into She-Hulk to stop her. It seems that Titania is holding a grudge of this defeat, and has decided that if she can’t beat Jen with her fists, she can do it with a legal injunction.

In some ways Titania’s lawsuit can almost be considered a reference to She-Hulk’s publishing origins. Decades before the premiere of She-Hulk: Attorney at Law, the possibility of another She-Hulk show, and copyright issues surrounding the name, inspired Marvel to create the character in the first place.

The origin of She-Hulk

In many ways She-Hulk exists because of the 1977 Incredible Hulk television series. Although the character never appeared on the critically acclaimed CBS show, the popularity of the series led to She-Hulk’s creation. Over on the ABC television network, a show called The Six Million Dollar Man had been a ratings bonanza, which led the network to create a female spin-off called The Bionic Woman. This move made Marvel Comics nervous.

According to Sean Howe’s book Marvel: The Untold Story, publisher Stan Lee was worried that CBS would copy ABC’s formula and commission a female Hulk spin-off. If CBS did this, then the copyright would go to Universal Television, the studio that produced the Hulk series. Lee wasn’t thrilled with the possibility of a Hollywood studio profiting off of a derivative Marvel character without the comic publisher getting a piece of the pie.

Stan Lee solved this problem by creating the character first, ensuring that Marvel Comics would own the copyright. She-Hulk would be one of the last major characters created by Stan Lee, who also wrote her debut issue. Savage She-Hulk #1 was published in November 1979 (cover-dated February 1980). David Anthony Kraft took over the series after the first issue.

“It was done under duress,” Kraft shared while speaking with Howe. “It was like ‘we need to create a character called the She-Hulk, and we need to get it out in the next 30 seconds.’ If you look at the first issue Stan did, there’s really nothing to it.”

Although Kraft’s run helped flesh out She-Hulk as a character, he initially saw her existence as gimmicky. “I grew up on Marvel Comics, and remembered Stan making fun of how DC had endless iterations of the characters: Super-Monkey, Super-Horse, and Streaky the Super-Cat and on and on. We were all pulling our hair out and wailing and bemoaning the day that Marvel had to create a She-Hulk.”

Despite Stan Lee’s concerns, CBS never commissioned a She-Hulk television series. In fact, She-Hulk would not receive her own television series until 2022, when Marvel Studios would produce one for Disney+. In a funny way, this brings things full circle.

What’s next for She-Hulk’s copyright battle?

If the fourth episode's cliffhanger is any indication, it looks like She-Hulk and Titania are heading for a rematch. Only this time they’ll be battling it out in legal proceedings instead of with their fists. Then again, this is She-Hulk we’re talking about, so it’s possible some physical blows might be traded in the courtroom again. Either way, things are going to get spicey when the hearings begin.

She-Hulk: Attorney at Law streams on Disney+ every Thursday through October 13.