My first thought is “computer memory” or a similar term would be read as structural in the ordinary meaning. To use it functionally in a means + function manner might be “means for storing binary data”. In that case only listed structures and equivalents would be included.
By the way, “DOE” doesn’t get you what you think it does in M+ function.
the “equivalents” of section 112 (it creates the means + function rules) is not actually the same as the Doctrine of Equivalents (DOE) equivalent. It is a complex area as seen in this quote from PatentlyO -
Means-plus-function claims are interpreted to cover only structures disclosed in the specification that perform the claimed function and, in addition, any equivalents of those disclosed structures. On its face, this appears duplicative of the traditional doctrine of equivalents (DOE). In this case, the Federal Circuit spells out some differences between the two. Most notably, “an equivalent structure [for means-plus-function analysis] under § 112 ¶ 6 must have been available at the time of the issuance of the claim, whereas the doctrine of equivalents can capture after-arising technology developed after the issuance of the patent.” This statement by the court does not, however, precisely explain the distinction. For means-plus-function claims, court precedent allows the doctrine of equivalents to only capture after-arising technology.
I think, in context, just “memory” works. You often see “sensor”, “receiver”, “transmitter”, “fastener” in claims. They are taken to be well understood physical objects, normally with no need of definition.
If in doubt, you can use different ways of including an element in different claims. More structural in one claim and functional in another claim.
In case the way you use “memory” in a claim is seen as functional by a judge you have the advantage of it not being “at the point of novelty”. Even though claims in the US are to taken as a whole, some judges analyses claims into old stuff and new stuff.
