The two initial Kerr black holes have total area
whereas the final Schwarzschild black hole has . Hawking's area theorem implies
Since , the radiated fraction is bounded by
This upper bound increases with and reaches
for two initially extremal holes, . For the final hole to be Schwarzschild, their spins must be oppositely directed so the total angular momentum vanishes. The bound assumes an idealized merger saturating the area law.

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