8. The apparatus of claim 7 wherein: the multimodal application comprises an X+V page that includes the voice activated hyperlinks; and each voice activated hyperlink further comprises an XHTML anchor element bound to a terminal element of the grammar by a value of an identifying attribute of the anchor element, the value of the identifying attribute being unique within the X+V page.
7. Apparatus for disambiguating a speech recognition grammar in a multimodal application, the multimodal application including voice activated hyperlinks, the voice activated hyperlinks being voice enabled by a speech recognition grammar comprising ambiguous terminal grammar elements, the multimodal application being operable in a multimodal browser on a multimodal device supporting multiple modes of user interaction with the multimodal device, the modes of user interaction including a voice mode and a visual mode, the multimodal browser being operatively coupled to a grammar interpreter, the apparatus comprising a computer processor and a computer memory operatively coupled to the computer processor, the computer memory having disposed within it computer program instructions capable of: maintaining by the multimodal browser a record of visibility of each voice activated hyperlink, the record of visibility including current visibility and past visibility on a display of the multimodal device of each voice activated hyperlink, the record of visibility further including an ordinal indication, for each voice activated hyperlink scrolled off display, of the sequence in which each such voice activated hyperlink was scrolled off display; recognizing by the multimodal browser speech from a user matching an ambiguous terminal element of the speech recognition grammar; and selecting by the multimodal browser a voice activated hyperlink for activation, the selecting being carried out in dependence upon the recognized speech and the record of visibility.