any strictly convex (concave) ⌧ guarantees that ˆ ⌧avg. is strictly greater [less] than ˆ ⌧mle. Proof By definition, ˆ ⌧avg. = E h ⌧ ⇣ ˜ ⌘i . Using Jensen’s inequality, we know that E h ⌧ ⇣ ˜ ⌘i > ⌧ h E ⇣ ˜ ⌘i , so that ˆ ⌧avg. > ⌧ h E ⇣ ˜ ⌘i . However, because ˜ ⇠ N h ˆmle, ˆ V ⇣ ˆmle ⌘i , E ⇣ ˜ ⌘ = ˆmle, so that ˆ ⌧avg. > ⌧ ⇣ ˆmle ⌘ . Of course, ˆ ⌧mle = ⌧ ⇣ ˆmle ⌘ by definition, so that ˆ ⌧avg. > ˆ ⌧mle. The proof for concave ⌧ follows similarly. ⌅