Bat-Girl isn't counted by DC as part of the Batgirl legacy, which officially goes Gordon>Bertinelli>Cain>Brown>(New 52 Flustercuck)>Gordon...
I agree with making Gordon the starting point, since she created the mantle for herself instead of it being a creation of Bruce. Which is why I disagree with them counting Helena, since she took up the identity without being asked by Gordon OR Wayne.
Bat-Girl wasn't part of that chain. She's Bat-Girl sidekick of Bat-Woman, not Batgirl independent heroine and sometime partner of the Batman. This matters.
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