is there any connection between Google update and applying adsense ?

hi
i am just trying to figure it out
is there any connection between Google update (Google Penguin 2.0 ) and applying Google adsense above site or article content
i know it is strange question but regarding to GWF i have read this replay from a top contributor

Looking at your homepage I see three leaderboard ads dominating the content above the fold. That tells me - and the algorithm - that you are more interested in visitors clicking on your ads than reading your content. If you really want visitors then put your content where visitors can see it, not hidden below your AdSense.

Click to expand...

what do u think about that ( red color line ) !!!!

Well, yeah if you stuff the top of your pages with tons of ads, that might get you some penalty at google