Supergirl fights to break free of Gorilla Grodd's control in "Belly of the Beast."
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Gorilla Grodd uses Supergirl for a short period to do his bidding. She breaks out of it when he tries to make her throw Linda's mother into a pit of fire. When she breaks out of it she has an intense fight with Grodd, strangely an icicle kills Grodd by piercing him into his head. This is not Kara's doing but most likely Buzz or someone higher working the chess board.