Surprisal theory holds that the human processing difficulty of a linguistic unit in context is an affine function of its surprisal under some language model. I argue this claim is a tautology without further constraint: for any non-negative difficulty measure over units in context, there exists a language model whose surprisal is an affine function of it under mild technical conditions. Therefore, because any pattern of difficulty is consistent with some language model, without an additional constraint on the language model, surprisal theory makes no falsifiable predictions. The tautology was long obscured by an assumption implicit in two decades of psycholinguistic work---that the relevant language model is the distribution that generated the training corpus, so that improving corpus fit improves predictions of human behavior. Recent empirical work has undermined this assumption, demonstrating that better corpus models can be worse predictors of processing difficulty. I conclude that breaking the tautology requires a rationalist intervention, i.e., the relevant language model must be derived from a non-empirically motivated model of the comprehender, which could be based on, for instance, memory constraints or processing goals, and that, thus, does not depend on the behavioral data surprisal theory is meant to explain.

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