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Thomas Jane was originally attached for the lead role, but he turned it down, stating that he thought the script was going in the wrong direction. He felt it was too "comic book," whereas he wanted a more gritty, realistic approach.

Doug Hutchison initially passed on the project because he didn't respond to the script nor the role of Looney Bin Jim. Director Lexi Alexander called him to pitch the movie and her vision and, by the end of their phone conversation, Hutchison had already changed his mind and accepted the role.

Dominic West originally passed on the villain role of Jigsaw. Paddy Considine was in talks to play the role, when Dominic West came back and accepted to play the part.

Director Lexi Alexander said that she was against using the Skull emblem on Ray Stevenson's costume. However, fans wanted it to be more prominent than it was in the 2004 film. She described this design as "pre-schoolish" in an interview and eventually compromised with a degraded and worn skull image (similar to the 2004 movie).

The Punisher movies are distributed by Lionsgate Films, who also distribute the Saw movies. Both movie series feature a homicidal villain nicknamed "Jigsaw" and both feature Julie Benz.

Sons of Anarchy creator Kurt Sutter wrote an R-rated draft that according to him "taking the Punisher character out of the comic books" and putting him into a real world drama set in the streets of New York. At the very last minute, the studio decided to revert back to Nick Santora's comic-book style script with the intention of creating a sequel from that. Disgusted with the actions by the studio, Sutter was offered a story credit, but refused, and demanded that his name omitted from the final credits.

The body count racked up by Ray Stevenson (The Punisher) is 81 confirmed kills, excluding the two cases where he shoots someone "on the same side."

Directer Lexi Alexander did uncredited writing for the film. She stated on the audio commentary that she wrote the scene where The Punisher (Ray Stevenson) is forced to either kill Angela (Julie Benz) and her daughter or Mirco (Wayne Knight).