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Pretty much any female who wrestles could be considered this though there are those who are more physical than others.
Chyna was really the first proper Action Girl in WWE at least in the Attitude Era. She was introduced as a bodyguard for Triple H and actively competed in the men's division, even capturing the Intercontinental title three times. She was also the first woman to compete in the Royal Rumble and King of the Ring tournament and even became number 1 contender to the WWE Championship.
Jacqueline Moore was another tough girl in WWE who was known for competing in plenty of intergender matches (she even won her second Women's title from a man, don't ask) and went on to briefly hold the Cruiserweight title.
Around 2002-ish WWE began making their women's division more about athleticism than eye candy and 2003 was definitely the peak of the women's division with the cream of the crop being Trish Stratus, Lita, Nidia, Victoria, Ivory, Molly Holly, Jazz and Gail Kim. Sadly this didn't last.
Many women's wrestling fans regard All Japan Women's Pro Wrestling in early-to-mid 90s as the Crowning Era of Awesome for women's professional wrestling, with stars such as Manami Toyota, Aja Kong, Bull Nakano, Akira Hokuto and Kyoko Inoue at the top of their game, and several contenders for "bast women's match of all time" (including Manami Toyota and Toshiyo Yamada's hair vs hair match, Toyota and Kyoko Inoue's 60-minute draw, and Akira Hokuto vs Shinobu Kandori at Dreamslam 1). AJW's 80s era tends to be considered the runner-up, with the Crush Gals (Lioness Asuka and Chigusa Nagayo) generating heat comparable to Hulk Hogan at the same time.
SHIMMER is a dedicated American women's wrestling promotion, emphasising wrestling ability over T&A.
Many more have now popped up such as Women Superstars Uncensored (WSU) and WILD Wrestling.
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