If you haven't read New Avengers #35, I'm going to discuss the issue a bit, including some spoilers, so be forewarned!!! Anyhow, in the issue, writer Brian Michael Bendis decides to show us just how bad The Hood is, by having him sneak into Tigra's apartment, beat the crap out of her while another guy videotapes them, while telling Tigra that if she ever interferes with a supervillain under his protection again, he'll kill her mother. The scene as written is pretty brutal, and artist Leinil Francis Yu adds a little bit more to it by sexualizing it a bit more than I think even Bendis intended (although I am uncertain about that - I know Bendis laid the basic scene out panel by panel, but I dunno what that entails).
Now here's my question - Bendis has apparently intimated that he will be having Tigra change sides and join the New Avengers, mostly as a result of this beating. Therefore, do you think that successfully takes something like this, which is about as "Women in Refrigerators" as you can get (Woman assaulted because, as Bendis himself points out, "[i]t was written to be disturbing," which is basically the whole point behind WiR - that you can gain an easy visceral reaction by having a woman brutalized) OUT of the WiR dynamic, by actually having Tigra's story be furthered with the beating having something to do with TIGRA? To wit, over in her first arc on Birds of Prey, Gail Simone had Black Canary kidnapped and severely beaten - but the scene wasn't what one would term WiR, because the incident was not designed to show, say, Green Arrow's reaction to the beating, or whatever, but strictly as part of a plot in Black Canary's own book - the same sort of thing you would see in any other male-starring comic book. Batman or Daredevil or whoever can be beaten down to show him coming back stronger after the beating - that's normal. That's not, say, Sue Dibny being raped to piss the Justice League off (and her never reacting to it or exploring it at ALL).
Tigra being brutalized to show Hood's prospective supervillain partners (and, later, the Avengers) how tough the Hood is ("Look! He beat the crap out of a WOMAN! And she didn't even get to fight back! He MUST be evil!") is bad.
Tigra being brutalized to further advance her development as a character - is that bad?
By the way, I don't really recommend you read it, but for further reading on this scene, check out this interview with Bendis. It is pretty darn annoying, especially as the interviewer really seems to bend over backwards with "Man, those crazy feminists might have a problem with this scene - aren't those feminists so crazy? What is their problem? How do you deal with such crazy feminists being so crazy about your scenes? They're just crazy, right?."