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I guess that kind of depends. I mean, long term Batman readers wouldn't think of her as obscure, I'm sure. Especially in the last four or five years (our time, not DC Universe time), she's played more of a role in events over the course of that time, especially in Robin's book.
In the past 3-4 years, she's been persona non grata except for the most minor of snippets. And if she hadn't died, but just been retired, she'd have just about faded entirely into the background.
But implied rape with a power drill on a teenage girl tends to make people remember a character.