Summary
This paper focuses on studying PAC-Bayes generalization bounds based on the Wasserstein distance. It introduces novel high-probability bounds applicable to both batch learning (i.i.d. setting) and online learning (non-i.i.d. setting). Unlike previous PAC-Bayes bounds, their bounds are not limited to bounded or sub-Gaussian losses. Furthermore, leveraging their theoretical findings, the authors propose a new SRM training strategy and provide empirical evidence to validate its effectiveness.
Strengths
Compared to previous results, the Wasserstein-distance PAC-Bayes bounds presented in this paper require fewer or weaker assumptions. Additionally, unlike previous PAC-Bayes bounds that typically invoke Gaussian distributions, their bounds accommodate discrete Dirac distributions for both the prior and posterior distributions.
Weaknesses
Regarding the Wasserstein regularization part, it might be necessary to empirically compare it with similar styles of regularization, such as weight decay $||w||$ and the 'distance to initialization' $||w-w_0||$. Although I believe that a data-dependent prior will provide a tighter bound, it is uncertain whether the data-dependent prior can significantly outperform a data-independent prior (e.g., $0, w_0$) considering the significantly increased computational time required.
Questions
Major concerns:
1. There might be a small error in Theorem 2: in the proof of Theorem 2 (Section B.2), you let $\lambda_i=\sqrt{\frac{\ln{(K/\delta)}}{|S_i|}}$ in the last step (i.e. Line 636). However, this choice does not yield the desired $\sum_{i=1}^K\sqrt{\frac{|S_i|\ln{(K/\delta)}}{m^2}}$ in your bound. If I understand correctly, you could consider setting $\lambda_i=\sqrt{\frac{2\ln{(K/\delta)}}{|S_i|}}$, which would result in the last term in the bound becoming $\sum_{i=1}^K\sqrt{\frac{2|S_i|\ln{(K/\delta)}}{m^2}}$. This may be the smallest achievable second term in Section B.2.
2. In Line 206-207, you argue that Eq. (3) contains a trade-off parameter $\lambda$, while Eq. (2) does not. However, it is worth noting that a similar parameter, $\epsilon$, is also involved in your practical training objective, namely Eq. (5). Therefore, the argument regarding the presence of $\lambda$ may not be entirely fair. Perhaps removing Line 206-207 could be considered?
3. Have you considered incorporating the empirical variance term into your algorithm? Since you emphasize its reliance on the prior rather than the posterior, I would appreciate it if you could demonstrate some practical implications.
4. Under the same conditions, such as bounded loss or even zero-one loss, is it possible to compare your Wasserstein-based PAC-Bayes bounds with the standard KL-based PAC-Bayes bounds, especially those that also include variance terms as mentioned in [1,2,3]?
Minor comments:
1. Line 131: there is a missing period after $S_K$.
2. RHS of the equation on Line 633: $L{|S_i|}\Longrightarrow L_{|S_i|}$.
3. RHS of the equation on Line 635: $\lambda [S_i|]\Longrightarrow \lambda |S_i|$.
[1] Seldin, Yevgeny, et al. "PAC-Bayesian inequalities for martingales." IEEE Transactions on Information Theory 58.12 (2012): 7086-7093.
[2] Tolstikhin, Ilya O., and Yevgeny Seldin. "PAC-Bayes-empirical-Bernstein inequality." NeurIPS 2013.
[3] Mhammedi, Zakaria, Peter Grünwald, and Benjamin Guedj. "PAC-Bayes un-expected Bernstein inequality." NeurIPS 2019.
Rating
7: Accept: Technically solid paper, with high impact on at least one sub-area, or moderate-to-high impact on more than one areas, with good-to-excellent evaluation, resources, reproducibility, and no unaddressed ethical considerations.
Confidence
4: You are confident in your assessment, but not absolutely certain. It is unlikely, but not impossible, that you did not understand some parts of the submission or that you are unfamiliar with some pieces of related work.
Limitations
There is no potential negative societal impact.