Yes I think this is one way to attack the argument but you have to break the circularity somehow. Many of the dismissals of the Hofstadter/Penrose argument I’ve read here, I think, do not appreciate the actual argument.
Without Penrose giving solid evidence people making counter arguments tend to get dismissive then sloppy. Why put in the time to make well tuned arguments filled with evidence when the other side does not bother after all.