The thing is that they have some but not all of the attributes of a super-villain.
A sea-raider who uses a stolen acid gun to build a psychically-controlled army of skeleton men? If only he had a name or had a bit more swagger! Alas for him the Shark puts him down before he could do enough to elevate himself out of this gathering of also-rans. (Amazing-Man Comics 021, 1941)
This gang of guys dressed as mailmen don't give the Blue Beetle much trouble even when wielding compressed air guns that fire explosive pellets. I admire the visual, though. (Big 3 005, 1941)
The Scooby-Doo style "fake haunting to drive people away from treasure/natural resource/property" is of course super-villain adjacent, but there are so many instances of in comics that I tend to disregard them as generic criminality. This unnamed fellow, however... not only was he attempting to scare off a homeowner so that he could look for pirate treasure in her basement but he went and "I would have gotten away with it..." -ed at that meddling Marvelo, Monarch of Magicians. (Big Shot Comics 009, 1941)
Just some nameless goons that take part in an usurpation attempt against Blue Bolt villain the Green Sorceress but they're Jack Kirby goons so they look fantastic. (Blue Bolt v1 004, 1940)
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