Abstract We develop a basic convergence analysis for an adaptive ${C}^{0}\mathsf{IPG}$ method for the biharmonic problem that provides convergence without rates for all practically relevant marking strategies and all penalty parameters assuring coercivity of the method. The analysis hinges on embedding properties of (broken) Sobolev and BV spaces, and the construction of a suitable limit space. In contrast to the previous convergence result of adaptive discontinuous Galerkin methods for elliptic PDEs, here we have to deal with the fact that the Lagrange finite element spaces may possibly contain no proper $C^{1}$-conforming subspace. This prevents from a straight forward generalization and requires the development of some new key technical tools.
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