fathom - 4:12 pm on Feb 5, 2013 (gmt 0)
No one but google "knows" for sure. You could and possibly are sending people in the wrong direction with your over zealous self belief that you are correct.
There is a lot of grey areas with google but they clearly write about using the disavow tool with PENGUIN on that blog post. What they do not differentiate is the difference between sites affected by the ALGO version or sites affected by the MANUAL version.
Thought I would over-capitalise to MAKE a point as well.
If you forced PENGUIN problems into domains (so you can learn) you might have a track record for fixing these problems though.