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I'm disappointed in you Kirk... I trust you to keep me up to date on this kind of thing, since I don't read comics or really visit the comic centric websites any longer. Still, this apparently happened in "Hulk", so I know that's not really your beat. I'd be happy to hear your thoughts on it though...
Apparently, some people are offended by a cowering, topless Silver Sable who showed up in Jeff Loeb's Hulk #17. I can't say I'm shocked (that they're offended)... and I'm not sure I've ever even read more than the briefest Sable cameo in a comic.
http://skew.dailyskew.com/2009/11/how-silver-sable-got-screwed-by-marvels.html
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he tends to give the artists he works with free reign to draw what they want and then adjusts his story around that. So its very likely its the artist (Ed McGuiness?) who chose to put Sable in such a... submissive pose.
But, yeah it's not a very faithful characterization. Silver has been portrayed in the stories I've read as someone who's tough as nails, and despite her looks and skintight bodysuit, not overtly sexual at all.