Posterior Frequencies and the Cost of Not Fitting: A Correction to a Memorization Lower Bound
Feldman (2021) gave an influential lower bound linking the cost of not fitting training labels to excess population risk via frequency-dependent coefficients $\tau_{n,\ell}$. This paper demonstrates that Feldman's central conditioning identity fails because the counts of other points convey information about the sampling distribution, and it provides an exact three-point counterexample together with an exponentially large multiplicative gap. The authors recover a valid bound within the same model by replacing the count-only coefficient with the exact full-sample posterior mean, which depends on both multiplicity and the complete frequency profile.
The paper rigorously disproves Lemma 2.1 and Theorem 2.3 of Feldman (2021). The exact three-point counterexample ($N=n=3$) with independent fair labels and a permutation-equivariant learner violates the claimed inequality, and Theorem 3 shows the ratio of the original penalty to actual excess risk can grow as $\frac{2}{15}(4/3)^n$, ruling out any universal positive constant-factor repair. The authors then recover a valid lower bound within the same normalized-weight model by replacing the count-only coefficient $\tau_{n,\ell}$ with the exact full-sample posterior mean $q_x(Z)$.
The counterexample in Section 3 is exceptionally clean and checkable by hand via exact arithmetic over eight raw-weight configurations. The corrected exact posterior decomposition (Theorem 4) is tight pointwise: for any observed point $x$, a learner can concentrate its entire excess risk on $x$, so the coefficient $q_x(Z)$ cannot be increased without violating universality.
The exponential failure mode uses a sample-size-dependent prior $\pi^{(n)}$, which correctly rules out a universal constant multiplier but does not imply the bound fails for any fixed long-tailed distribution of practical interest. The corrected coefficients depend on the full frequency profile rather than just multiplicity, making them harder to compute and deploy in downstream analyses; the paper explicitly leaves open the recovery of Feldman's noisy-label, privacy, and subpopulation extensions. Moreover, the corrected bound is fundamentally a lower bound on excess risk for unrestricted learners, so its implications for specific algorithm classes remain indirect.
The evidence directly supports the core claims. The exact-arithmetic certificate in Appendix A makes the three-point counterexample fully verifiable without code. The authors fairly situate their result within the literature, distinguishing their fixed-sample-size, learner-dependent criterion from classical Dirichlet characterizations (Johnson's sufficientness postulate) and noting that the original $\tau_{n,\ell}$ is an occupancy-weighted average of the corrected profile coefficients. They also responsibly identify which intermediate calculations in Feldman's work survive the correction.
The paper provides enough detail for independent reproduction of the central results. The counterexample requires only evaluating eight normalized vectors with rational weights, supported by an exact-arithmetic certificate. For general priors, Proposition 10 reduces the corrected coefficients to one-dimensional integrals, and the authors report quadrature cross-checks with discrepancies below $10^{-15}$. However, no source code or data repository is referenced, and the exponentially large gap relies on careful asymptotic leading-term analysis whose finite-$n$ values (e.g., $n=32$ giving ratio $\approx 1234.9$) are given but not accompanied by runnable scripts.
Feldman's memorization lower bound assigns a frequency coefficient based on how often a point appears in the training sample. We give an exact three-point counterexample to its conditional and averaged forms, using independent fair labels and a permutation-equivariant learner. A sequence of sampling priors makes the ratio of the proposed penalty to actual excess risk grow exponentially, ruling out a universal positive constant-factor repair. The priors vary with sample size, the offending profiles become rare, and both quantities vanish. Retaining the original model, we obtain an exact replacement using full-sample posterior probabilities. Under exchangeability, these depend on multiplicity and the complete frequency profile. We characterize the largest multiplicity-only coefficients valid for unrestricted learners. The original coefficient has the posterior-mean form of Good's exact frequency formula and is an occupancy-weighted average of the corrected coefficients.
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