I think so, yes.
Question is, whether the office supplies company was directly advertising using misleading adcopy (by advertising prescription drugs) - in this case it's plain stupid, because virtually nobody who is interested in prescription drugs buys a toner cartridge instead. The conversion rate must be very low and may indeed lead to a low EPC. But again, it's just stupid, because the conversion IS low.
Or did the misleading adcopy lead to an MFA/arbitrage page on office supplies, and THE NEXT CLICK (e.g. processed through Overture) leads to the office supplies site. In this case it would be very close to fraud.