__ Summary and Contributions__: This paper studies the implicit bias of SGD, and show that for a fairly large class of learning problems, the SGD outputs a solution that can not be a solution of a regularized problem.

__ Strengths__: This paper provides a very interesting results on the implicit bias of algorithm. Instead of studying one specific scenario of implicit bias, the author study whether implicit bias exists for a very general class of learning problems (even though in the convex setting this is highly non-trivial). The negative results in the paper provide a very interesting direction to the community that one should seek other alternatives as explaining the generalization property of SGD.

__ Weaknesses__: I enjoy reading this paper a lot. I do not see great limitations here.

__ Correctness__: The paper is technically correct.

__ Clarity__: Smooth and well written.

__ Relation to Prior Work__: Yes the author clearly discuss the relation with previous works.

__ Reproducibility__: Yes

__ Additional Feedback__:

__ Summary and Contributions__: The authors study the limitations of implicit regularization in the general setting of stochastic convex optimization (SCO) and in particular, study the question of whether generalization of SGD in the SCO setting can be explained ONLY via implicit regularization and not some other mechanisms. The primary contribution is demonstrating that, in certain regimes, the (averaged) output of SGD is not a solution to a regularized empirical risk minimization problem for a large class of regularizers. The results of this paper establish a form of separation between explicit and implicit regularization.

__ Strengths__: Implicit regularization is an active area of reserach that has been attracting increasingly more attention in the machine learning community over the past years. The results are novel and interesting and this is the first work to study implicit regularization in the setting of stochastic convex optimization. Given the recent NeurIPS publications on implicit regularization, the general theme that this work is trying to address is pertinent to the NeurIPS community.

__ Weaknesses__: While the investigated questions are interesting and important, I have some concerns regarding the correctness of the proofs as well as several claims made by the authors throughout the text. See my answers below for details.

__ Correctness__: 1) The problem domain W is a closed and bounded subset of R^{d} (lines 126-127), yet the definition of SGD output (Eq. (2)) as well as GD output (Eq. (4)) does not project onto W. The domain of regularizer is also assumed to be W (see line 172). If definitions (2) and (4) are not a typo, this raises important issues regarding correctness of the proofs. See the point below.
2) In Line 191, strongly convex regularizers are also assumed to be 1-Lipshitz. This is impossible on unbounded domains (i.e., if SGD iterates or output is not projected onto W). I have not checked the proofs in detail, but here is an example where a proof step appears to be incorrect. In the extended version of the paper, appendix B.1, the equation following (33) applies strong convexity to the SGD output w_S defined in (2) without proving that it is inside the set W.
3) Please explain in what sense does Theorem 1 imply that generalization of SGD cannot be explained via implicit bias point of view. A concrete example would be helpful, as the it is unclear why Theorem 1 would rule out implicit bias point of view towards explaining generalization. I.e., even if algorithm does not return a minimum norm solution, maybe it is biased towards solutions with small enough norm. A concrete, formal example following Theorem 1 would be very helpful.
4) Note that implicit bias of iterative algorithms is ITERATION DEPENDENT. Hence, even if optimization path of SGD exactly coicided with regularization path of ridge regression, you could prove statements such as the one in Theorem 1 (for any fixed regularizer lambda*||w||_{2}^{2}, after enough iterations, SGD output will incur a larger regularization penalty that that of corresponding ridge regression solution).
5) The assumption r(0) = 0 is not as mild as it seems, since SGD is naturally biased towards points with small training loss. I.e., intially, very large and crude steps will be taken to go far away from 0, which can be seen as r(0) being large.

__ Clarity__: The writing could be significantly improved. Below I list some examples that interferred with the reading.
The Euclidean norm is undefined.
Lines 116-117: Explain what you mean by the phrase "perhaps in the strictest sense". What is this "sense"? How does it relate to your work? Is it the strictest sense or not?
Line 121: Explain what you mean by "unstable convex problem". An algorithm can be unstable, how can a problem be unstable? In what sense are the problems considered in the submitted paper are stable?
Line 181: Explain what you mean by "almost wlog". In my opinion, quite a lot of generality is lost by the assumption r(0) = 0 (see the section on correctness above).
Line 181: Phrases like "perhaps somewhat stronger" are unhelpful. Is the assumption stronger or not?
Line 190-191: A family of regularizers that is both strongly convex and Lipshitz is not a "natural family of regularizers". Strong convexity and lipshitzness can only hold on bounded domains, thus even ridge regression does not fall within such a setup.
Line 213: I belive "comparable penalty" should be "the same" penalty, since the definitino (6) also requires the "training loss"/"empirical error" to be smaller than the one that is returned by the algorithm in question.
Line 275: The constraint set "unit ball" is refered to as a "regularizer", whereas previously regularizer was a function denoted by r( ).
Line 279: Unfinished sentence.
There are several issues with the therorem statements. I will focus on Theorem 1 for concreteness.
a) T = Omega(1/(lambda * eta)) is ambiguous. I believe you should replace = with >=, since otherwise the theorem statement is meaningless.
b) Theorem statements are missing quantifiers. For instance, in Theorem 1, you should say whether the result holds for ANY step size eta in the given range or just for SOME particular eta in the given range.
c) It seems that you use \Theta notation to denote NON-NEGATIVE functions, please mention that somewhere.

__ Relation to Prior Work__: It is clear how this work differs from the prior literature, since it is the first one to study implicit regularization in the setting of stochastic convex optimization. However, the related literature section could be improved.
First, implicit regularization dates back to much earlier works than the ones concerning neural networks (the first theoretical work on implicit regularization is due to Buhlmann and Yu 2003 "Boosting with the l2 loss"). Given that the work the authors present has little or nothing to do with neural networks, the related work section should be expanded to include other authors who developed the theory of implicit regularization for gradient descent over the past ~20 years. Also, it is worth noting that one of the central reasons motivating the sutudy of early stopping and implicit regularization is the computational efficiency of the method in comparison to the explicit regularization schemes.
Second, the authors should elaborate in more details what is meant by "an attempt towrads separation between learnability and regularization" (line 110). In my opinion, such a separation is not established in the submitted work (see my questions above).
Third, the paragraph concerning stability, in addition to the clarity concerns raised above, is missing some imporant works. For instance, Hardt, Recht and Singer 2015 "Train faster generalize better" and Chen, Jin and Yu 2018 "Stability and Convergence Trade-off of Iterative Optimization Algorithms" should both be cited and put into an appropriate context regarding your work.
Finally, given that the submitted work is fundamentally trying to establish a form of separation between explicit and implicit regularization, other important results are missing. For instance, Ali, Kolter and Tibshirani 2019 "A Continuous-Time View of Early Stopping for Least Squares" paper shows that for linear models, gradient descent, along its optimization path, is closely related to the regularization path of ridge regression, through the lens of excess risk of obtained models. Other examples also exist, for instance, the works of Raskutti, Wainwright and Yu 2014 "Early stopping and non-parametric regression: An optimal data-dependent stopping rule" and Wei, Yand and Wainwright 2017 "Early stopping for kernel boosting algorithms: A general analysis with localized complexities" show that early stopped gradient descent can be analyzed via the same statistical tools as the correspondig explicitly regularized problems over Euclidean balls.
My overall impression is that authors are unfamiliar with several important results in the implicit regularization literature, which in turn hinders the presentation and the ability to put the submitted work into an appropriate context.
In addition to the above, could the authors please elaborate on two claims in the introduction:
lines 20-23: could the authors please cite some references where neural networks are trained without any regularization (no early stopping, no dropout, no weight decay, etc.) and yet they achieve a remarkable performance?
lines 28-29: could the authors please clarify on the exact result in the book [4], where it is shown that implicit regularization is IDENTICAL to explicit l2 regularization? The only results I know show that implicit regularization is SIMILAR to explicit l2 regularization (and identical in some regimes only. e.g., running gradient descent to convergence on underdetermined linear systems of equations with the quadratic loss is equivalent to the ridge regularization path in the limit lambda-> 0).

__ Reproducibility__: Yes

__ Additional Feedback__: ----- UPDATE AFTER READING THE AUTHORS' RESPONSE -----
I thank the authors for their thorough response, which I have read in detail, and, which has clarified several of my questions.
I am, however, not convinced that the proofs can be fixed as easily as the authors claim, as it seems that there is loss of generality in using different radiuses for the constraint set of SGD iterates and that of the regularized solution. it is not enough that the iterates stay in a constant size ball (changing the radius of the ball will also change the optimal regularized solution). A direct analysis of projected SGD would be difficult, since the favourable expressions for unconstrained SGD iterates obtained in Theorem 8 would no longer apply.
Also, I do not agree with the third point in the authors response, on that the authors "do not claim that generalization cannot be explained via implicit bias". Indeed, such a claim is made even in the abstract (lines 11-12), and multiple times throughout the text.
Overall, I think that the paper is promising and interesting, but it needs to undergo a serious revision and another round of reviews that would ensure its correctness.
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For convenience of the authors, all of my primary concerns raised above are numbered. Subject to the authors response, I am willing to increase the score, most importantly, if the authors address the correctness issues and also, if the authors are willing to improve the literature review and put the submitted work into a better context, in particular, with respect to the prior works investigating connections between explicit and implicit regularization. However, in its current presentation the paper looks closer to a draft rather than a finished work and the overall writing needs to be significantly improved before publication (see the section on clarity).
Some typos:
Line 162: R -> R^{d}
Line 292: refers -> refer
Line 343: attain -> attains

__ Summary and Contributions__: UPDATE:
One of the reviewers points out that projection steps are not being taken. The authors mostly brush off the reviewer's concerns about projection. However, in our discussion we could not resolve the issues using the authors logic in the rebuttal. Therefore, I decided to lower my score.
I find the topic to be very interesting and am looking forward to seeing a revised version of this submission.
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Neyshabur, Tomioka, and Srebro argued in their paper "In Search of the Real Inductive Bias: On the Role of Implicit Regularization in Deep Learning" that the risk of networks trained by SGD did not obey the usual bias--variance tradeoff: SGD was seen to train larger and larger networks without overfitting. Their hypothesis was that SGD likely introduced some sort of implicit bias/regularization, much like it did in simple linear models. By studying this implicit bias, we might understand the generalization mystery behind deep learning.
This work studies implicit bias/regularization, but does so in a setting that is often considered to be extremely well understood, namely stochastic convex optimization. In this setting, the authors show that there are distributions where SGDs behavior cannot be explained in terms of an implicit regularization, complicating the idea that implicit regularization surely explains generalization in the more complex setting of deep learning.
The first result shows that distribution dependence is necessary in the sense that, for every distribution-independent regularizer, there is a distribution on instances where SGDs find solutions that are suboptimal in terms of both empirical risk and the regularization penalty. The second result looks at distribution-dependent regularizers and shows that there exists a data distribution, for which every (now distribution-dependent) regularizer cannot explain generalization. More formally, the level set defined by SGDs solution and the regularized loss, contains classifiers with small empirical risk and large risk. Both of these results are in the overparameterized setting. The authors also study convex learning problems with dimensionality smaller than the number of training points.

__ Strengths__: Theoretical results are novel and may potentially have broad impact. Prior work has ruled out specific regularizers, while this work introduces claims about all possible regularizers. I think this work is very timely because the theory of deep learning faces a number of major hurdles that seem to be distracting us from essential lessons. By returning to a well-known stochastic convex optimization setting, the authors have made nice progress.

__ Weaknesses__: The paper does not resolve the obstructions that it uncovers, although I do not see this as a serious problem.

__ Correctness__: I am not aware of any serious issues with correctness. However, the statement of Theorem 4 and its use of Definition 1 seems to have some potential issues. Note that the notion of a "statistically complex" set implies the existence of a distribution D that satisfies some properties. By the order of quantifiers, though, this is a different distribution than the distribution D in the statement of the Theorem 4. Is that meant to be? In Definition 1, K looks like a nonrandom set, whereas in Theorem 4 it is a random set (i.e., measurable with respect to the sample). Indeed, the quantification going on in Theorem 4 is very informal and needs to be rewritten more formally, because the current quantification explain whether the quantification over the regularizer happens before or after the sample is chosen.

__ Clarity__: Overall, I found the paper to be clearly written. I list a few places where clarity could be improved.
It would be useful to see a short description of the key properties of the data distribution that allows one to obtain the result in Theorem 4. Too many details are deferred to the supplement.
Theorem 4 has several issues (raised above). The statement could also be made more clear by specifying the relationship between d and T and what variables are being taken to infinity in the asymptotic expression \Theta(1): just d, or d and T at some rate?

__ Relation to Prior Work__: To the best of my knowledge, the authors mention key relevant work and place their work in the context of others.

__ Reproducibility__: Yes

__ Additional Feedback__:

__ Summary and Contributions__: The paper provides very interesting negative results on the question of implicit regularization of SGD for the non-trivial problem of stochastic convex optimization.

__ Strengths__: 1. The authors make a good choice of setting (SCO) that allows them to derive strong negative results, i.e. ruling out large classes of regularizers by showing Pareto-sub-optimality of the SGD solutions.
2. The paper is technically strong and makes substantial novel contributions.
3. The authors are careful not to overstate their results and limitations are made very clear. (I very much appreciate such intellectual honesty in a time where this can no longer be considered a given)
4. The constructions are quite general and it seems this opens up avenues for analysis of other models beyond SCO.
5. The paper is very well written and a pleasure to read.

__ Weaknesses__: As almost every well-founded approach, one needs to simplify the problem considered in exchange for getting strong and meaningful results. One could wish for a setting that is closer to "deep ML practice".

__ Correctness__: Yes.

__ Clarity__: Yes, very much so.

__ Relation to Prior Work__: Yes.

__ Reproducibility__: Yes

__ Additional Feedback__: