brinked - 6:12 pm on Oct 22, 2012 (gmt 0)
Keep in mind that sites will creep up in between panda and penguin updates. I see 1 webmasters who always ranks top 5 for a search term. Then every panda update that site gets pummeled. A few weeks later he will have another site ranking top 5...and then that gets demolished by the next update.
I had a pandalized site taken offline for a year...I put it back up and it was recovered...until the next panda refresh that is.
So if sites creep up in between updates, if they are really low quality, chances are they will get taken out by the next update around the corner.