If I understand this correctly, it seems like the researchers were just stimulating vocal areas of the bird brains--which to me seems like an entirely different thing than implanting memories into the bird's brain. If you stimulate my motor cortex in a way that makes me kick my leg, it would be a little silly to say that you implanted a memory of me kicking--the memory is something that occurs after the fact. Maybe the original article makes this distinction a little clearer?