It's not disingenuous, it's just plain incorrect. :)
The panda algorithm is believed to specifically target duplicate content.
My dictionary website was Panda-penalized because it showed citations of slang use from books, news articles, TV shows, movies, etc. The citations were loaded via AJAX.
I have more details in a prior comment on this post, here: https://news.ycombinator.com/item?id=9977372