Mostly this, though it's not so black-and-white. The paper discusses results from a DNN-HMM system (Maas et al., using Kaldi) trained on 2k hours, and it does provide a small generalization improvement over 300 hours.

Much of the excitement about deep learning -- which we see as well in DeepSpeech -- is that these models continue to improve as we provide more training data. It's not obvious a priori that results will keep getting better after thousands of hours of speech. We're exited to keep advancing that frontier.