True, but at the time of writing -- Lykos named himself Sauron in X-Men vol.01:no.60 (September 1969) -- The Silmarillion had not yet been published. That was released September 1977, eight years later.
I'm imagining him eagerly buying a copy from the first print run (or maybe stealing it, he's a supervillain), huge Tolkein fan that he apparently is, reading, reading, reading... "Son of a--!"
And then some would-be supervillain in Dubuque who tries to rob banks with a Silly Putty gun calls himself Melkor. Sauron rips up the paper and stomps out, ignoring Barbarus saying, "Um, I hadn't done the crossword yet..."
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