>>7688508miniatures toys always existed though.
Hasbro created the term "action figure" for GI Joe, because it was literally a doll, back in the 1960s.
Also, the term "doll" is a large blanket term that is applied to all human type toys, because it's a tax/tariff term. So even inarticulated miniatures are considered dolls by the US government.
However, clowns do not count as dolls, even when they're literal dolls. Nor are XMen, Spiderman, Fantastic Four, etc, even when they're literal dolls.
Toy Biz beat the US government.