I think to be qualified as memory ... that the thought of the past would have to be recoverable at any time for any purpose. It would have to be something a mind could dwell on and think of for the sake of the thought alone. So usually we associate the word memory with self-cognition and consciousness. On the other hand, I do you see your point. In a conditioned response the information of what to respond to and how to respond lie within brain tissues of the conditioned animal. In as much as this is true we can compare it with a computer which is a machine that stores information. We call that information storage "memory". So what distinguishes the computer from us is our ability to think for the sake of thought itself. Much of our own brains functions occur without us having to think or being aware of the functions requiring attention. So the idea of conditioned response lies within this area of function.