In the process of Batman creating failsafe plans to stop Justice Leaguers in the event that one of them went rogue (a process that would later lead to the Tower of Babel incident), Batman's artificially constructed Zur-En-Arrh persona activated and created an android capable of stopping him in case Batman ever took a life. Zur-En-Arrh created Failsafe using technology from various cybernetic villains previously faced by the Justice League, including Amazo. Failsafe remained dormant in the Batcave for years until The Penguin faked his own death and framed Batman for homicide. While there were provisions in its programming for Batman being framed, unfortunately, they needed to be activated by the late Alfred Pennyworth.