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I think my optical stats professor said that the lower limit, or the best you could do, was defined by the Cramer-Rao Bound. It’s a bit tough to wade through, but there’s a discussion of it on Wikipedia. I think it basically says that no matter what you do, you can’t do better than this. Now I have no idea how close modern denoising algorithms are to that bound. Apparently that author thinks we can move closer to it.
Mark—Thanks very much for providing the link.