Off-policy learning, the task of evaluating and improving policies using historic data collected from a logging policy, is important because on-policy evaluation is usually expensive and has adverse impacts. One of the major challenge of offpolicy learning is to derive counterfactual estimators that also has low variance and thus low generalization error. In this work, inspired by learning bounds for importance sampling problems, we present a new counterfactual learning principle for off-policy learning with bandit feedbacks. Our method regularizes the generalization error by minimizing the distribution divergence between the logging policy and the new policy, and removes the need for iterating through all training samples to compute sample variance regularization in prior work. With neural network policies, our end-to-end training algorithms using variational divergence minimization showed significant improvement over conventional baseline algorithms and is also consistent with our theoretical results.
In this paper the authors studied the problem of off-policy learning, in the bandit setting when a batch log of data generated by the baseline policy is given. Here they first summarize the surrogate objective functions derived by existing approaches such as importance sampling and variance regularization (Swaminathan et. al). Then they extend the results in Theorem 2 of the paper by Cortes et. al (which also uses the empirical Bernstein inequality by Maurer and Pontil), and derive a new surrogate objective function that involves the chi-square divergence. Furthermore, the authors also show that the lower bound of this objective function can be iteratively approximated by variational f-GAN techniques, which could potentially be more numerically stable and empirically has lower variance. 
In general, I think the problem studied in this paper is very interesting, and the topic of counterfactual learning, especially policy optimization with the use of offline and off-policy log data, is important. However, I think the theoretical contribution in this paper on off-policy learning is quite incremental. Also the parts that involve f-GAN is still questionable to me.
Detailed comments:
In these variance regularization formulations (for example the one proposed in this paper, or the one derived in Swaminathan's paper), \lambda can be seen as a regularization parameter that trades-off bias and variance of the off-policy value estimator R(h) (for example the RHS of equation 6). To exactly calculate \lambda either requires the size of the policy class (when the policy class is finite), or the complexity constants (which exists in C_1 and C_2 in equation 7, but it is not clearly defined in this paper). Then the main question is on how to choose \lambda such that the surrogate objective function is reasonable. For example in the safety setting (off-policy policy learning with baseline performance guarantees, for example see the problem setting in the paper by P. Thomas 2015: High Confidence off-policy improvement), one always needs the upper-bound in 6) to hold. This makes the choice of \lambda crucial and challenging. Unfortunately I don't see much discussions in this paper about choosing \lambda, even in the context of bias-variance trade-offs. This makes me uncomfortable in believing that the results in experiments hold for other (reasonable) choices of \lambda.
The contribution of this paper is of two-fold: 1) the authors extend the results from Cortes's paper to derive a new surrogate objective function, and 2) they show how this objective can be approximated by f-GAN techniques. The first contribution is rather incremental as it's just a direct application of Theorem 2 in Cortes's paper. Regarding the second contribution, I am a bit concerned about the derivations of Equation 9, especially the first inequality and the second equality. I see that the first inequality is potentially an application of the conjugate function inequality, but more details are needed (f^* is not even defined). For the second equality, it's unclear to me how one can swap the sup and the E_x operators. More explanations are definitely needed to show their mathematical correctness, especially when this part is a main contribution.  Even if the derivations are right, the f-GAN surrogate objective is a lower bound of the surrogate objective function, while the surrogate function is an upper bound of the true objective function (which is inaccessible). How does one guarantees that the f-GAN surrogate objective is a reasonable one? 
Numerical comparisons between the proposed approach, and the approach from Swaminathan's paper are required to demonstrate the superiority of the proposed approach. Are there comparisons in performance between the approach from the original chi-square surrogate function and the one from the f-GAN objective (in order to showcase the need of using f-GAN) as well?
Minor comments:
In experimental section, method POEM is not defined.
The paper is in an okay status. But there are several minor typos, for example \hat{R}_{(} in page 3, and several typos in Algorithm 1 and Algorithm 2.
In general, I think this paper is studying an interesting topic, but the aforementioned issues make me feel that the paper's current status is still unsuitable for publication.