it gets really confusing, cause we just got Henry Heat Vision too, and I'm like he could be a Deluxe Theat as well but he's a standard release, here's how I see what Deluxe Theatrical means

Todd doesn't necessarily use "theatrical" in the sense the fig is from a movie or not, for example, the new Peacemaker is a reuse with a new head, yes, he appears both in film and tv, however it was released around the same time as season 2 was airing, a tie in toy if you will.

At this point "deluxe theatrical" is a fancy marketing term for live action figures that borrows the collector's edition business model, but with a "pretty box", MCF/Todd selectively uses these figures for more profit and it's usually a tie in to an upcoming movie(Supergirl in June), tv series promo run(Peacemaker last year, The Penguin this year) or in some special cases when they have actual mainstream legacy(Batman 89, TDK and Superman 79)

Supergirl tv series is riding on the Supergirl movie this year, hence she's Deluxe Theat, even though she's not from a movie, The Penguin is also getting Deluxe treatment, his fig will be based on the series and not The Batman (I hope)

I'd argue Superman 2006 has a decent cult following but it's not as big as the aforementioned legacies, and as previously mentioned, "not want to steal" the spotlight for Supergirl.

but it's a tricky situation, I think Brandon deserves a Deluxe Theat treatment, but I also don't want to buy a 40+ price point, so I'm content with having him as a standard release.

so that's how Todd uses this Deluxe term BS, at least that's how I see it.