I can confirm this as a user...no testing equipment, just my eyes. At 25% brightness on the SP4 I had bad eye strain just like I had with the Dell u2412M monitors. Last two nights I put the Surface Pro 4 brightness setting on 50% and also 56% and I did not suffer any eye strain. I guess I cannot use it for low light reading...for now anyway.
I am starting to get buyers remorse with this thing and I am within my 30 day return policy. Just too many issues that could be hardware and not fixable through firmware/software updates.