I fail to see how any tactic that involves going around in circles over enemy territory until you get low on fuel can be much use. Once you form the circle, you are effectively a fixed target. Your opponent has two choices: (a) station enough aircraft above the circle to make whoever breaks out first a dead duck. Then wait for volunteers. Or more subtle, pull back far enough that the first pilot to break from the circle stands a decent chance of getting away...
Either way, as long as the Bf-110s are circling, they are making things worse for themselves. Tactics like his only make sense in situations of near absolute air superiority.
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