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If you are referring specifically to scrawny action heroines, then they look like they don't work out because they don't.

However, if you're referring to modern heroines in general, then your question is not true for all modern heroines. Look at Halle Barry in Catwoman, Milla Jovovic on Resident Evil, etc. Those women are in great physical shape, and although they are thin, you can tell they do work out.

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