Yeah related to this: another interpretation of this paper's findings could be that what's important is not listening per se, merely putting the other person's interests above your own. For example, if I hear and remember every word you say but am still very adamant about putting in my two cents for ego reasons, then yes, I did listen but I'm still putting myself first.
So I agree with you in the sense that merely letting the other person speak and giving them enough attention to appear like you're listening is still putting their interests first. Though, if you're already there, why not actually listen? Or if you really don't want to listen, sounds like not a great relationship...