We present an argument based on the multidimensional and the uniform central limit theorems, proving that, under some geometrical assumptions between the target function and the learning class , the excess risk of the empirical risk minimization algorithm is lower bounded by \[\frac{\mathbb{E}\sup_{q\in Q}G_q}{\sqrt{n}}\delta,\] where is a canonical Gaussian process associated with (a well chosen subset of ) and is a parameter governing the oscillations of the empirical excess risk function over a small ball in .
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