I've seen this claim from a couple of low end SEO companies. I don't believe them, because they also claim only high end link building yet they interlink their clients' websites. But....
Do you believe anyone actually is able to recover from Panda, repeatedly? i.e. that they've figured it out to the point where they're not just guessing? Maybe the high end SEO companies have it figured out but aren't telling?
It's rubbish. What happens? Get your good ranking back, then a few geeks review your site, it gets dumped to a few pages back where it rightfully belongs. Afterall, if it was good on its own merits, would you need the help of an SEO company?
These pronouncements are just more of the same. I think that one of the (many) reasons for Panda is because of the unrelenting spam mail that everyone was receiving in the past few years that "guaranteed" a first page placement on Google. I got at least one a day, sometimes more. They still trickle in, but not like before (thankfully). Google was aware of these unrealistically boastful solicitations and struck them dead. But unfortunately, in their carpet bombing campaign, they've killed a lot of bystanders too.