Large sites, which are generally forums or "community" generated content, pretty much all had issues with thin content and duplicate content that could be cleaned up if there was some genuine value at the core. But large sites that were driven by syndicated garbage or scraped product reviews would be out of luck. On the other hand, small sites that have no thin content or duplicate content can't clean up when there's nothing to clean.
And I think I mentioned in another thread that I didn't do any work on my sites, post-Panda, for nearly six months, until my hobby site recovered on its own. I wouldn't be surprised if many other small sites took the same approach. I just spent tons of time filing DMCA notices.