Abstract: Bounds on the smallest eigenvalue of the neural tangent kernel (NTK) are a key ingredient in the analysis of neural network optimization and memorization. However, existing results require distributional assumptions on the data and are limited to a high-dimensional setting, where the input dimension $d_0$ scales at least logarithmically in the number of samples $n$. In this work we remove both of these requirements and instead provide bounds in terms of a measure of distance between data points: notably these bounds hold with high probability even when $d_0$ is held constant versus $n$. We prove our results through a novel application of the hemisphere transform.