Jon C. Barlow, Natural History of the Bell Vireo…
“ I am not fully convinced that song from the nest is simply a "foolish" habit, since snakes, the principal predators with which this species has to contend, are deaf. My own field observations and the circumstances of the innumerable instances recorded in the literature of male vireos singing from the nest suggest that this is a function of the proximity of the observer. As mentioned elsewhere, vocal threat is the initial as well as the primary means by which territory is maintained. Song from the nest evoked by an enemy also serves to alert the female to danger. ”
