Future Noir Scarlett is basically Black Widow, but I'm okay with that. When you consider the origin of the G.I.Joe comic as a failed pitch for a Nick Fury based team book, it seems likely that she was based off Black Widow to begin with, so why not?
I used the Heroclix Manhunter, which tool some work since she had a textured mask. I had to sand the face a little which resulted in a little loss of detail. I used a small piece of a paperclip to make the bow on her arm.
More office supplies put to good use.