I'm not disputing you can establish an upper bound on latency. You can always do this by using a system's slowest component as the upper bound and pin everything else's latency to that bound, as I said. I'm just pointing out that this upper bound a) doesn't scale well/leaves a lot of performance on the floor, and b) the upper bound is very sensitive to size and geometry.

In high performance systems, constant time random access is just not constant.