**K**lebanov and co-authors from Berlin arXived this paper a few weeks ago and it took me a quiet evening in Darjeeling to read it. It starts with the premises that led Robbins to introduce empirical Bayes in 1956 (although the paper does not appear in the references), where repeated experiments with different parameters are run. Except that it turns non-parametric in estimating the prior. And to avoid resorting to the non-parametric MLE, which is the empirical distribution, it adds a smoothness penalty function to the picture. (**Warning:** I am not a big fan of non-parametric MLE!) The idea seems to have been Good’s, who acknowledged using the entropy as penalty is missing in terms of reparameterisation invariance. Hence the authors suggest instead to use as penalty function on the prior a joint relative entropy on both the parameter and the prior, which amounts to the average of the Kullback-Leibler divergence between the sampling distribution and the predictive based on the prior. Which is then independent of the parameterisation. And of the dominating measure. This is the only tangible connection with *reference priors* found in the paper.

The authors then introduce a non-parametric EM algorithm, where the unknown prior becomes the “parameter” and the M step means optimising an entropy in terms of this prior. With an infinite amount of data, the true prior (meaning the overall distribution of the genuine parameters in this repeated experiment framework) is a fixed point of the algorithm. However, it seems that the only way it can be implemented is via discretisation of the parameter space, which opens a whole Pandora box of issues, from discretisation size to dimensionality problems. And to motivating the approach by regularisation arguments, since the final product remains an atomic distribution.

While the alternative of estimating the marginal density of the data by kernels and then aiming at the closest entropy prior is discussed, I find it surprising that the paper does not consider the rather natural of setting a prior on the prior, e.g. via Dirichlet processes.

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