Membership inference attacks (MIAs) pose a critical privacy threat to fine-tuned large language models (LLMs), especially when models are adapted to domain-specific tasks using sensitive data. While prior black-box MIA techniques rely on confidence scores or token likelihoods, these signals are often entangled with a sample's intrinsic properties - such as content difficulty or rarity - leading to poor generalization and low signal-to-noise ratios. In this paper, we propose ICP-MIA, a novel MIA framework grounded in the theory of training dynamics, particularly the phenomenon of diminishing returns during optimization. We introduce the Optimization Gap as a fundamental signal of membership: at convergence, member samples exhibit minimal remaining loss-reduction potential, while non-members retain significant potential for further optimization. To estimate this gap in a black-box setting, we propose In-Context Probing (ICP), a training-free method that simulates fine-tuning-like behavior via strategically constructed input contexts. We propose two probing strategies: reference-data-based (using semantically similar public samples) and self-perturbation (via masking or generation). Experiments on three tasks and multiple LLMs show that ICP-MIA significantly outperforms prior black-box MIAs, particularly at low false positive rates. We further analyze how reference data alignment, model type, PEFT configurations, and training schedules affect attack effectiveness. Our findings establish ICP-MIA as a practical and theoretically grounded framework for auditing privacy risks in deployed LLMs.
Lu et al. (Thu,) studied this question.