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Design is very hard to verbally describe, and AI doesn't have good judgement on what is easy to use or attractive.

I think it's because it's non-deterministic too. You can't iteratively improve design the same way you can code.

If they wanted couldn't they do something like RLHF? Instead of humans picking the best of 2 text outputs, they pick the best rendered design

I'd be very surprised if they're not already doing this.