Ok, DNA changes occur, but physiological writing to the DNA does not happen in humans. I'll give you DNA repair, BCR/TCR rearrangement, meiosis, and also the more recently discovered LINE-1 retrotransposons - but they occur at specific times and usually in a random fashion. I don't think this fits any idea of what memory is.

If you're saying it's theoretically possible, I would agree that it might be, and that there is a potential for DNA to be memory. But to claim that DNA is memory without a known write process is premature I think.