We study the relationship between gradient-based optimization of parametric models (e.g., neural networks) and optimization of linear combinations of random features. Our main result shows that if a parametric model can be learned using mini-batch stochastic gradient descent (bSGD) without making assumptions about the data distribution, then with high probability, the target function can also be approximated using a polynomial-sized combination of random features. The size of this combination depends on the number of gradient steps and numerical precision used in the bSGD process. This finding reveals fundamental limitations of distribution-free learning in neural networks trained by gradient descent, highlighting why making assumptions about data distributions is often crucial in practice. Along the way, we also introduce a new theoretical framework called average probabilistic dimension complexity (adc), which extends the probabilistic dimension complexity developed by Kamath et al. (2020). We prove that adc has a polynomial relationship with statistical query dimension, and use this relationship to demonstrate an infinite separation between adc and standard dimension complexity.

We present and study approximate notions of dimensional and margin complexity, which correspond to the minimal dimension or norm of an embedding required to approximate, rather then exactly represent, a given hypothesis class. We show that such notions are not only sufficient for learning using linear predictors or a kernel, but unlike the exact variants, are also necessary. Thus they are better suited for discussing limitations of linear or kernel methods.