Summary
The paper analyses two estimators of the Fisher Information matrix and specifically their variances, which (from reference 37) have closed-form but non-practical expressions. The authors show a sequence of inequalities and derive practical bounds for these variances, both element-wise and trace-wise, both conditioned to x and not. Several remarks and trade-offs on these bounds clarify when an estimator is preferable over the other.
The results hold in the general exponential family likelihood but are also further concretized for regression and classification.
Strengths
The paper is overall very well written and structured.
Notation is clear, results are properly presented and every step is further clarified in the appendix. \
The alternation between formal statements and explanations is great and makes the paper vey pleasant to read. I particularly like the amount of remarks and observations that discuss specific terms of the equations, explains them and connect them to each other. And the same is true for all the highlighted trade-offs (for example line 212-215)
Weaknesses
I have found no major weaknesses in the paper. I report some minor things.
I personally dislike the notation $\hat{\mathcal{I}}_1(\theta_i)$ for the i-th element of the diagonal introduced in line 87. This notation suggest that this term only depends on $\theta_i$, but it actually depends on the whole $\theta$ vector. On the other hand, this is quite a light easy notations, and I can't think of alternatives which are not much heavier to read.
Also, I find the definition in line 120 "is defined by $\hat{\mathcal{I}}_j(\theta_i)$ with $x=x_1=...=x_N$" to be yes understandable but not super clean. The alternatives are not as compact, but I'd recommend using the extra space to clarify this a bit better. At least you should write that $y_1,...,y_N$ are i.i.d. from $p(y|x;\theta)$ and not from $p(y,x;\theta)$ as in $\hat{\mathcal{I}}_j(\theta_i)$.
It would be nice to explicitly write the proof for the variance closed expression in Lemma B.1, yet clarifying that it's not a paper contribution. This is for two reasons: (1) it would make the paper self contained, without the need for the reader to read reference 37 and (2) the notation is slightly different and it would be easier for the reader to be consistent.
Questions
In line 168. Shouldn't "of Eqs. (4) and (6)" instead be "of Eqs. (4) and (5)"? And consistently shouldn't "$\mathcal{V}_1(\theta_i|x)$" be "$\mathcal{V}_2(\theta_i|x)$"? \
I ask this because "small shifts in parameter space yield large changes in the output" to me refers to the magnitude of the network jacobian $||\partial_i h(x)||$, and that appear in the bound for $V_1$, not for $V_2$. Am I misunderstanding something or is this a typo?
In line 246. Isn't the bound sample complexity $\mathcal{O}(\frac{1}{N_x} + \frac{1}{N_y})$? I can't see why it should be the product, can you elaborate more on this derivation?
Limitations
I think it would be nice to clarify better that the work is incremental on "Soen et all - On the variance of the Fisher information for deep learning" [reference 37] and their closed form expression reported in the appendix in Lemma B.1. (also it would be nice to move these closed form expressions to the main paper).