We prove an Omega(d/log(sw/nd)) lower bound for the average-case cell-probe complexity of deterministic or Las Vegas randomized algorithms solving approximate near-neighbor (ANN) problem in ddimensional Hamming space in the cell-probe model with w-bit cells, using a table of size s. This lower bound matches the highest known worst-case cell-probe lower bounds for any static data structure problems.

This average-case cell-probe lower bound is proved in a general framework which relates the cell-probe complexity of ANN to isoperimetric inequalities in the underlying metric space. A tighter connection between ANN lower bounds and isoperimetric inequalities is established by a stronger richness lemma proved by cell-sampling techniques.