About four years before another certain superhero discovered he was just a character in a comic book, a villain in Fat Ninja, published by Silverwolf Comics, was clued into the exact same thing:
from Fat Ninja #3 by Gary Amaro and Emilio Soltero
Compared to the rest of the Silverwolf/Greater Mercury output, Fat Ninja was one of the better titles, with an appealing cartoony style and a tongue very firmly in cheek. Think a slightly less-silly Tick.