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We address the problem of defending predictive models, such as machine learning classifiers (Defender models), against membership inference attacks, in both the black-box and white-box setting, when the trainer and the trained model are publicly released. The Defender aims at optimizing a dual objective: utility and privacy. Both utility and privacy are evaluated with an external apparatus including an Attacker and an Evaluator. On one hand, Reserved data, distributed similarly to the Defender training data, is used to evaluate Utility; on the other hand, Reserved data, mixed with Defender training data, is used to evaluate membership inference attack robustness. In both cases classification accuracy or error rate are used as the metric: Utility is evaluated with the classification accuracy of the Defender model; Privacy is evaluated with the membership prediction error of a so-called "Leave-Two-Unlabeled" LTU Attacker, having access to all of the Defender and Reserved data, except for the membership label of one sample from each. We prove that, under certain conditions, even a "naïve" LTU Attacker can achieve lower bounds on privacy loss with simple attack strategies, leading to concrete necessary conditions to protect privacy, including: preventing over-fitting and adding some amount of randomness. However, we also show that such a naïve LTU Attacker can fail to attack the privacy of models known to be vulnerable in the literature, demonstrating that knowledge must be complemented with strong attack strategies to turn the LTU Attacker into a powerful means of evaluating privacy. Our experiments on the QMNIST and CIFAR-10 datasets validate our theoretical results and confirm the roles of over-fitting prevention and randomness in the algorithms to protect against privacy attacks.