(Action v1 011, 1939)
There are basically three levels of Zatara enemy: unpowered crooks such as the Tigress (MSV 019) or the Ghost (MSV 021) or a million gangsters over the years who are wildly outclassed and only have a chance if they manage to get the jump on him; villains of roughly equal or even greater power to him such as the Mad Lama (MSV 031) and finally folks like the Mad Lama's minions: armed with one really good trick that can give them a situational edge against him. The latter are generally the most entertaining, as rather than toying with them like a mouse or bringing all he resources to bear on a genuine threat, he is often forced to take some time to figure out what's going on. Which brings us to Madame Kelly.
Madame Kelly is a magic-using spy who wears cute outfits while trying to steal some defense plans that are being transported by cruise ship. Her only demonstrated power is to summon an illusory ghost, which she uses as a distraction while she hunts for her target below decks. Zatara spends a fair bit of the story stumped because he can't banish what isn't actually a ghost. It's fun stuff! They should BRING HER BACK
ADDENDUM: Gentle reader, I present to you the sea-ghost of Madame Kelly:
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