Implicit in your comment is that any suggestion of malicious intent by the author is not substantive. That doesn't seem reasonable, given the context.
This is precisely why we're stuck where we are in the first place. If you allow people to call "dog whistle language" and attribute "malicious intent disguised as thoughtful rethoric", you give everyone a fully general counterargument against anything. I could accuse you right now of using "dog whistle language" and there's literally nothing you can do to prove me wrong.
Those ideas are conversational equivalent of bioweapons. Once people start to use them, everyone loses.
What you're doing is, ironically, actually an attempt to shut down discussion. You're basically saying that an entire 50+ year historical record of politics in America isn't appropriate to bring up because, you claim, it might be used inappropriately to simply shut down debate.
No it isn't. It's a failure to acknowledge the reality of society we live and the language that powers and enables the status quo. It's an uncomfortable truth and one that has been painstakingly dug up over decades, but for every two steps forward on this subject the powers that be cause us to take one step back. Your unwillingness to substantially acknowledge such realities is what is stagnating this conversation, because certain ideas and solutions need to be repeated over and over again and sometimes re-branded to make it more appealing to people who don't want to address the problems present in our society.
Here we have a "memo" that uses credible science but has conclusions and ideas completely detached from that science, and then when it is pointed out how incredibly shit his conclusions are, it suddenly becomes an issue about "free speech." It's pretty akin to the whole "states rights" branding that happens with certain other political conversations. It IS dog-whistle language and utilizing such language while pretending you're not, and even worse pretending like you're actually making a point, is incredibly counter-productive to advancing anywhere on gender/sexual issues for everyone. It's dishonest at worst and ignorant at best.
This whole topic has PG's psuedo-philosophical musing's stink all over it and it's quite nauseating to have to dig through it. It's the bullshit asymmetry principle in action.