I was thinking the same thing yesterday, but I don't think Penny is their next Joker or Iron Man. But you're right, he's got so many faces in the movies that I could see HT making a second one using the same body with two different heads. Personally, I think the smiley face is the best representation of the character, and the sewer base, the boat and red ballon make this release a "definitive" representation of the character. The skateboard is the only Accessory from Chap 2 and it honestly seems pointless. Everything else is from part one.
I was thinking that it could've been a DX instead, with movable eyes, which would've been an appropriate feature for this character. But is Penny and the movies popular enough for HT to make more than one figure? I don't know.