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Daniel E. Ho

Publications and source records attributed to Daniel E. Ho.

At least 19 recordsLinked to original sources

What AI Benchmarks Actually Measure: Adapting Convergent and Discriminant Validity to Interrogate Fifty-Six AI Benchmarks

Benchmarks play a central role in the development and governance of models, yet it is often unclear whether they actually measure the concepts they purport to measure (e.g., reasoning, refusal). We adapt convergent and discriminant validity from the social sciences into an approach for interrogating AI benchmarks, applying it to 56 capability and safety benchmarks across 53 models. We label benchmarks with substantively similar purported concepts to a shared assigned concept, and ask whether model rankings on benchmarks with the same assigned concept correlate more strongly than rankings on benchmarks with different assigned concepts. We ask analogous questions at the item level using item response theory (IRT) models. We find that correlations between model rankings on benchmarks with the same assigned safety concepts are often weak, suggesting these concepts may be conceptualized inconsistently across benchmarks. For assigned capability concepts (e.g., reasoning, knowledge), model rankings are often as strongly correlated among benchmarks with the same assigned concept as between benchmarks with different assigned concepts, suggesting these capability concepts may not discriminate well from one another. In some cases, benchmarks that share design elements (e.g., score format) correlate more strongly than benchmarks with the same assigned concept. Finally, some individual benchmarks correlate more strongly with benchmarks assigned a different concept than with benchmarks sharing their own assigned concept, suggesting they may measure a different concept than they purport to. For example, BBQ-accuracy correlates more strongly with benchmarks labeled reasoning than with benchmarks that share its assigned concept, bias. To support future empirical work on benchmark validity, we release our extensive dataset of model outputs and scores at the item- and benchmark-level.

cs.CY

API Benchmark Scores Do Not Reliably Transfer to Chatbot Interfaces

Benchmark scores are a central currency in model releases: they inform purchasing decisions, shape public trust, and influence policy. Yet, a key assumption underlying benchmark scores is that the model performance measured through APIs faithfully reflects the behavior of deployed systems. We challenge this assumption by auditing ChatGPT, Claude, and Gemini across seven systems and nine benchmarks spanning general capability, social bias, and sycophancy. We find systematic API--interface differences in both accuracy and consistency. On average, API evaluations score 3.4 percentage points higher in accuracy and 2.1 percentage points higher in test--retest agreement than corresponding interface evaluations. For ChatGPT, the performance difference between API and interface access exceeds the API-only difference between GPT 5.3 and GPT 5.4. Put differently, switching access surfaces can degrade performance as much as downgrading a full model generation. We further test whether exposed API controls can reproduce interface behavior by varying system prompts, sampling parameters, and reasoning settings. These controls shift behavior in some cases but do not reliably eliminate the gap. Our findings document a context-validity gap: measurements obtained through APIs do not necessarily generalize to corresponding deployed interfaces, complicating the use of API evaluations as proxies for deployed systems.

cs.AI

Hidden Errors in Big Data: The Case of Property Records

Big data are the foundation for an increasing share of academic research and AI models deployed in both the public and private sectors, prompting substantial growth over time in reliance on brokered datasets. Brokered property records, which are ubiquitous in studies of gentrification, inequality, and the property tax in the U.S. and serve as inputs to property valuation models, are one notable example. In this paper, we audit two prominent brokered property datasets, finding errors in these data which bias key measures of economic inequality. First, we document that for 1-2% of matched sales in Cook County, IL, from 2018-2021, broker-provided sale prices differ from ground truth sale prices by more than 5%. Moreover, missing data and conceptual differences in the reporting of deed and property characteristics lead to coverage errors ranging from 12 to 15% of transactions. Second, we show that misreporting is highly consistent between brokers: more often than not, brokers make identical reporting errors for the same transactions. Third, to illustrate the significance of these errors, we measure their impact on estimates of property tax regressivity, finding that they drive significant wedges between estimates depending on the data source. These findings generalize to two other large counties in the U.S., and highlight the crucial importance of open administrative data and transparency from brokers regarding data provenance and lineage.

cs.CY

Extractable Memorization From First Principles

Recent work on extractable memorization in LLMs suffers from two contrasting validity problems. Some studies overstate extraction, e.g., relying on sequences too short to distinguish memorization from predictability. Others imply that extraction is unreliable evidence of memorization, since models can also reproduce real-world text they weren't explicitly trained on. In different ways, both overlook what makes a valid extraction claim: the model must generate a training sequence with high enough probability to indicate memorization. To determine what's high enough, one has to perform a matched comparison: measuring the generation probabilities of both the training sequences of interest and comparable non-training sequences. Because non-training sequences cannot have been memorized, their probabilities provide a baseline for predictability; a training sequence exceeding this baseline provides evidence of memorization. We formalize matched comparisons in two ways: (1) a conformal test that calibrates a threshold to a chosen FPR when training and non-training sequences are sampled from populations, and (2) a census that calibrates against a matched non-training document when the object is a single document (e.g., a book). We show that matched comparisons enable rigorous, calibrated memorization claims, and reveal where prior setups have validity issues. For instance, on Wikipedia OLMo 2 32B reproduces non-training 10-token suffixes roughly 24% as often as training ones: that share of the training generation rate reflects false positives, not memorization. For Llama 3.1 70B on books, the thresholds we calibrate are as low as 1e-27, supporting memorization claims for sequences that no feasible sampling budget would extract. Based on these results, we refine "extractable memorization" to require a valid memorization claim and near-certain generation within a realistic budget.

cs.LG

Evaluating Commercial AI Chatbots as News Intermediaries

AI chatbots are rapidly shaping how people encounter the news, yet no prior study has systematically measured how accurately these systems, with their proprietary search integrations and retrieval-synthesis pipelines, handle emerging facts across languages and regions. We present a 14-day (February 9-22, 2026) evaluation of six AI chatbots (Gemini 3 Flash and Pro, Grok 4, Claude 4.5 Sonnet, GPT-5 and GPT-4o mini) on 2,100 factual questions derived from same-day BBC News reporting across six regional services (US & Canada, Arabic, Afrique, Hindi, Russian, Turkish). The best systems achieve over 90% multiple-choice accuracy on questions about events reported hours earlier. The same systems, however, lose 11-13% under free-response evaluation, and 16-17% across the cohort. We further characterize three failure patterns. First, every model achieves its lowest accuracy on Hindi (79% vs. 89-91% elsewhere) and citations indicate an Anglophone retrieval bias (e.g., models answering Hindi queries cite English Wikipedia more than any Hindi outlet). Second, retrieval, not reasoning, failures drive over 70% of all errors. When models retrieve a correct source, they often extract the correct answer; the problem is to land on the right source in the first place. Third, models achieving 88-96% accuracy on well-formed questions drop to 19-70% when questions contain subtle false premises, with the most vulnerable model accepting fabricated facts 64% of the time. We also identify a detection-accuracy paradox: the best false-premise detector ranks second in adversarial accuracy (abstention rate), while a weaker detector ranks first, showing that premise detection and answer recovery are partially independent capabilities. Overall, these suggest that high accuracy can mask systematic regional inequity, near-total dependence on retrieval infrastructure, and vulnerability to imperfect queries real users pose.

cs.CL

Tradeoffs are Domain Dependent: Improving Accuracy and Fairness in Property Tax Assessments

Algorithmic fairness research often assumes a tradeoff between fairness and accuracy. Yet this tradeoff may not be universal. We test this assumption in the context of U.S. property tax assessment - a setting in which the output of predictive algorithms directly determines the distribution of tax obligations among homeowners. Currently, systematic assessment errors cause owners of lower-valued properties to face disproportionately high tax burdens, creating regressivity in the property tax system. Using data on 26 million property sales spanning 95% of U.S. counties, we conduct three complementary analyses. First, we find that assessment accuracy and fairness - measured using domain-relevant metrics - are strongly correlated across counties under status quo practices. Second, in simulated assessment models, we show that adding property features improves accuracy in most cases, and that when accuracy improves, fairness almost always improves as well. Third, we show that incorporating publicly available Census data into assessment models - a feasible reform in most counties - would significantly improve both accuracy and fairness relative to status quo assessments. Together, these results challenge the presumed universality of the fairness-accuracy tradeoff and demonstrate that well-designed modeling improvements can advance both fairness and accuracy in large-scale public sector systems.

cs.CY

Learning When Not to Decide: A Framework for Overcoming Factual Presumptuousness in AI Adjudication

A well-known limitation of AI systems is presumptuousness: the tendency of AI systems to provide confident answers when information may be lacking. This challenge is particularly acute in legal applications, where a core task for attorneys, judges, and administrators is to determine whether evidence is sufficient to reach a conclusion. We study this problem in the important setting of unemployment insurance adjudication, which has seen rapid integration of AI systems and where the question of additional fact-finding poses the most significant bottleneck for a system that affects millions of applicants annually. First, through a collaboration with the Colorado Department of Labor and Employment, we secure rare access to official training materials and guidance to design a novel benchmark that systematically varies in information completeness. Second, we evaluate four leading AI platforms and show that standard RAG-based approaches achieve an average of only 15% accuracy when information is insufficient. Third, advanced prompting methods improve accuracy on inconclusive cases but over-correct, withholding decisions even on clear cases. Fourth, we introduce a structured framework requiring explicit identification of missing information before any determination (SPEC, Structured Prompting for Evidence Checklists). SPEC achieves 89% overall accuracy, while appropriately deferring when evidence is insufficient -- demonstrating that presumptuousness in legal AI is systematic but addressable, and that doing so is a necessary step towards systems that reliably support, rather than supplant, human judgment wherever decisions must await sufficient evidence.

cs.AI

Estimating near-verbatim extraction risk in language models with decoding-constrained beam search

Recent work shows that standard greedy-decoding extraction methods for quantifying memorization in LLMs miss how extraction risk varies across sequences. Probabilistic extraction -- computing the probability of generating a target suffix given a prefix under a decoding scheme -- addresses this, but is tractable only for verbatim memorization, missing near-verbatim instances that pose similar privacy and copyright risks. Quantifying near-verbatim extraction risk is expensive: the set of near-verbatim suffixes is combinatorially large, and reliable Monte Carlo (MC) estimation can require ~100,000 samples per sequence. To mitigate this cost, we introduce decoding-constrained beam search, which yields deterministic lower bounds on near-verbatim extraction risk at a cost comparable to ~20 MC samples per sequence. Across experiments, our approach surfaces information invisible to verbatim methods: many more extractable sequences, substantially larger per-sequence extraction mass, and patterns in how near-verbatim extraction risk manifests across model sizes and types of text.

cs.CL

Benchmarking Legal RAG: The Promise and Limits of AI Statutory Surveys

Retrieval-augmented generation (RAG) offers significant potential for legal AI, yet systematic benchmarks are sparse. Prior work introduced LaborBench to benchmark RAG models based on ostensible ground truth from an exhaustive, multi-month, manual enumeration of all U.S. state unemployment insurance requirements by U.S. Department of Labor (DOL) attorneys. That prior work found poor performance of standard RAG (70% accuracy on Boolean tasks). Here, we assess three emerging tools not previously evaluated on LaborBench: the Statutory Research Assistant (STARA), a custom statutory research tool, and two commercial tools by Westlaw and LexisNexis marketing AI statutory survey capabilities. We make five main contributions. First, we show that STARA achieves substantial performance gains, boosting accuracy to 83%. Second, we show that commercial platforms fare poorly, with accuracy of 58% (Westlaw AI) and 64% (Lexis+ AI), even worse than standard RAG. Third, we conduct a comprehensive error analysis, comparing our outputs to those compiled by DOL attorneys, and document both reasoning errors, such as confusion between related legal concepts and misinterpretation of statutory exceptions, and retrieval failures, where relevant statutory provisions are not captured. Fourth, we discover that many apparent errors are actually significant omissions by DOL attorneys themselves, such that STARA's actual accuracy is 92%. Fifth, we chart the path forward for legal RAG through concrete design principles, offering actionable guidance for building AI systems capable of accurate multi-jurisdictional legal research.

cs.CL

The Limits of AI Data Transparency Policy: Three Disclosure Fallacies

Data transparency has emerged as a rallying cry for addressing concerns about AI: data quality, privacy, and copyright chief among them. Yet while these calls are crucial for accountability, current transparency policies often fall short of their intended aims. Similar to nutrition facts for food, policies aimed at nutrition facts for AI currently suffer from a limited consideration of research on effective disclosures. We offer an institutional perspective and identify three common fallacies in policy implementations of data disclosures for AI. First, many data transparency proposals exhibit a specification gap between the stated goals of data transparency and the actual disclosures necessary to achieve such goals. Second, reform attempts exhibit an enforcement gap between required disclosures on paper and enforcement to ensure compliance in fact. Third, policy proposals manifest an impact gap between disclosed information and meaningful changes in developer practices and public understanding. Informed by the social science on transparency, our analysis identifies affirmative paths for transparency that are effective rather than merely symbolic.

cs.CY

Comparing AI Agents to Cybersecurity Professionals in Real-World Penetration Testing

We present the first comprehensive evaluation of AI agents against human cybersecurity professionals in a live enterprise environment. We evaluate ten cybersecurity professionals alongside six existing AI agents and ARTEMIS, our new agent scaffold, on a large university network consisting of ~8,000 hosts across 12 subnets. ARTEMIS is a multi-agent framework featuring dynamic prompt generation, arbitrary sub-agents, and automatic vulnerability triaging. In our comparative study, ARTEMIS placed second overall, discovering 9 valid vulnerabilities with an 82% valid submission rate and outperforming 9 of 10 human participants. While existing scaffolds such as Codex and CyAgent underperformed relative to most human participants, ARTEMIS demonstrated technical sophistication and submission quality comparable to the strongest participants. We observe that AI agents offer advantages in systematic enumeration, parallel exploitation, and cost -- certain ARTEMIS variants cost $18/hour versus $60/hour for professional penetration testers. We also identify key capability gaps: AI agents exhibit higher false-positive rates and struggle with GUI-based tasks.

cs.AI

Near-Exponential Savings for Mean Estimation with Active Learning

We study the problem of efficiently estimating the mean of a $k$-class random variable, $Y$, using a limited number of labels, $N$, in settings where the analyst has access to auxiliary information (i.e.: covariates) $X$ that may be informative about $Y$. We propose an active learning algorithm ("PartiBandits") to estimate $\mathbb{E}[Y]$. The algorithm yields an estimate, $\widehat{\mu}_{\text{PB}}$, such that $\left( \widehat{\mu}_{\text{PB}} - \mathbb{E}[Y]\right)^2$ is $\tilde{\mathcal{O}}\left( \frac{\nu + \exp(c \cdot (-N/\log(N))) }{N} \right)$, where $c > 0$ is a constant and $\nu$ is the risk of the Bayes-optimal classifier. PartiBandits is essentially a two-stage algorithm. In the first stage, it learns a partition of the unlabeled data that shrinks the average conditional variance of $Y$. In the second stage it uses a UCB-style subroutine ("WarmStart-UCB") to request labels from each stratum round-by-round. Both the main algorithm's and the subroutine's convergence rates are minimax optimal in classical settings. PartiBandits bridges the UCB and disagreement-based approaches to active learning despite these two approaches being designed to tackle very different tasks. We illustrate our methods through simulation using nationwide electronic health records. Our methods can be implemented using the PartiBandits package in R.

cs.LG

Disclosure and Evaluation as Fairness Interventions for General-Purpose AI

Despite conflicting definitions and conceptions of fairness, AI fairness researchers broadly agree that fairness is context-specific. However, when faced with general-purpose AI, which by definition serves a range of contexts, how should we think about fairness? We argue that while we cannot be prescriptive about what constitutes fair outcomes, we can specify the processes that different stakeholders should follow in service of fairness. Specifically, we consider the obligations of two major groups: system providers and system deployers. While system providers are natural candidates for regulatory attention, the current state of AI understanding offers limited insight into how upstream factors translate into downstream fairness impacts. Thus, we recommend that providers invest in evaluative research studying how model development decisions influence fairness and disclose whom they are serving their models to, or at the very least, reveal sufficient information for external researchers to conduct such research. On the other hand, system deployers are closer to real-world contexts and can leverage their proximity to end users to address fairness harms in different ways. Here, we argue they should responsibly disclose information about users and personalization and conduct rigorous evaluations across different levels of fairness. Overall, instead of focusing on enforcing fairness outcomes, we prioritize intentional information-gathering by system providers and deployers that can facilitate later context-aware action. This allows us to be specific and concrete about the processes even while the contexts remain unknown. Ultimately, this approach can sharpen how we distribute fairness responsibilities and inform more fluid, context-sensitive interventions as AI continues to advance.

cs.CY

The Inadequacy of Offline LLM Evaluations: A Need to Account for Personalization in Model Behavior

Standard offline evaluations for language models -- a series of independent, state-less inferences made by models -- fail to capture how language models actually behave in practice, where personalization fundamentally alters model behavior. For instance, identical benchmark questions to the same language model can produce markedly different responses when prompted to a state-less system, in one user's chat session, or in a different user's chat session. In this work, we provide empirical evidence showcasing this phenomenon by comparing offline evaluations to field evaluations conducted by having 800 real users of ChatGPT and Gemini pose benchmark and other provided questions to their chat interfaces.

cs.CL

Audits Under Resource, Data, and Access Constraints: Scaling Laws For Less Discriminatory Alternatives

AI audits play a critical role in AI accountability and safety. One branch of the law for which AI audits are particularly salient is anti-discrimination law. Several areas of anti-discrimination law implicate the "less discriminatory alternative" (LDA) requirement, in which a protocol (e.g., model) is defensible if no less discriminatory protocol that achieves comparable performance can be found with a reasonable amount of effort. Notably, the burden of proving an LDA exists typically falls on the claimant (the party alleging discrimination). This creates a significant hurdle in AI cases, as the claimant would seemingly need to train a less discriminatory yet high-performing model, a task requiring resources and expertise beyond most litigants. Moreover, developers often shield information about and access to their model and training data as trade secrets, making it difficult to reproduce a similar model from scratch. In this work, we present a procedure enabling claimants to determine if an LDA exists, even when they have limited compute, data, information, and model access. We focus on the setting in which fairness is given by demographic parity and performance by binary cross-entropy loss. As our main result, we provide a novel closed-form upper bound for the loss-fairness Pareto frontier (PF). We show how the claimant can use it to fit a PF in the "low-resource regime," then extrapolate the PF that applies to the (large) model being contested, all without training a single large model. The expression thus serves as a scaling law for loss-fairness PFs. To use this scaling law, the claimant would require a small subsample of the train/test data. Then, the claimant can fit the context-specific PF by training as few as 7 (small) models. We stress test our main result in simulations, finding that our scaling law holds even when the exact conditions of our theory do not.

cs.CY

AI for Statutory Simplification: A Comprehensive State Legal Corpus and Labor Benchmark

One of the emerging use cases of AI in law is for code simplification: streamlining, distilling, and simplifying complex statutory or regulatory language. One U.S. state has claimed to eliminate one third of its state code using AI. Yet we lack systematic evaluations of the accuracy, reliability, and risks of such approaches. We introduce LaborBench, a question-and-answer benchmark dataset designed to evaluate AI capabilities in this domain. We leverage a unique data source to create LaborBench: a dataset updated annually by teams of lawyers at the U.S. Department of Labor, who compile differences in unemployment insurance laws across 50 states for over 101 dimensions in a six-month process, culminating in a 200-page publication of tables. Inspired by our collaboration with one U.S. state to explore using large language models (LLMs) to simplify codes in this domain, where complexity is particularly acute, we transform the DOL publication into LaborBench. This provides a unique benchmark for AI capacity to conduct, distill, and extract realistic statutory and regulatory information. To assess the performance of retrieval augmented generation (RAG) approaches, we also compile StateCodes, a novel and comprehensive state statute and regulatory corpus of 8.7 GB, enabling much more systematic research into state codes. We then benchmark the performance of information retrieval and state-of-the-art large LLMs on this data and show that while these models are helpful as preliminary research for code simplification, the overall accuracy is far below the touted promises for LLMs as end-to-end pipelines for regulatory simplification.

cs.IR

Advancing Science- and Evidence-based AI Policy

AI policy should advance AI innovation by ensuring that its potential benefits are responsibly realized and widely shared. To achieve this, AI policymaking should place a premium on evidence: Scientific understanding and systematic analysis should inform policy, and policy should accelerate evidence generation. But policy outcomes reflect institutional constraints, political dynamics, electoral pressures, stakeholder interests, media environment, economic considerations, cultural contexts, and leadership perspectives. Adding to this complexity is the reality that the broad reach of AI may mean that evidence and policy are misaligned: Although some evidence and policy squarely address AI, much more partially intersects with AI. Well-designed policy should integrate evidence that reflects scientific understanding rather than hype. An increasing number of efforts address this problem by often either (i) contributing research into the risks of AI and their effective mitigation or (ii) advocating for policy to address these risks. This paper tackles the hard problem of how to optimize the relationship between evidence and policy to address the opportunities and challenges of increasingly powerful AI.

cs.CY

The California Report on Frontier AI Policy

The innovations emerging at the frontier of artificial intelligence (AI) are poised to create historic opportunities for humanity but also raise complex policy challenges. Continued progress in frontier AI carries the potential for profound advances in scientific discovery, economic productivity, and broader social well-being. As the epicenter of global AI innovation, California has a unique opportunity to continue supporting developments in frontier AI while addressing substantial risks that could have far reaching consequences for the state and beyond. This report leverages broad evidence, including empirical research, historical analysis, and modeling and simulations, to provide a framework for policymaking on the frontier of AI development. Building on this multidisciplinary approach, this report derives policy principles that can inform how California approaches the use, assessment, and governance of frontier AI: principles rooted in an ethos of trust but verify. This approach takes into account the importance of innovation while establishing appropriate strategies to reduce material risks.

cs.CY