^...but that almost seems like a manual penalty situation compared to penguin (which is automated). Reconsideration's don't work for Penguin (at least aren't supposed to). The trick is finding people who recovered by disavowing (or scrubbing) from Penguin, which I'm not sure exist.
Penguin 2.0 has to be a PR disaster for google. It basically says, if you honestly clean up your mistakes, we'll still punish you. But if used artificial back-linking schemes (as long as they are high quality), we'll reward you with great rankings.
Has anybody tried removing their disavows to see what would happen?