The November 10, 1940 Spirit section has a character that looks like the Phantom Lady:
But they didn't begin publishing Phantom Lady stories until August 1941 in POLICE COMICS, so they didn't have the Phantom Lady when this Spirit story came out.
Will Eisner actually took credit for the creation of the Phantom Lady, but the original version of the character's costume bore less resemblance to the Eisner character we're talking about .
However, the redesigned Phantom Lady they had in the Fox comics could have been influenced by the look of the earlier Eisner villainess.
Phantom Lady:
http://en.wikipedia.org/wiki/Phantom_Lady
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