"It’s been reported that you will only be able to play as Catwoman in Batman if you have a new copy of the game.
Those buying a new copy will receive a code which will allow them to play as Catwoman, allowing for access to her Challenge Room levels and her unique part in the story.
Although Catwoman will still appear in the game if you don’t have an online pass, you will not be able to play as her unless you enter the code."