Of course. But depending on context the use and quoting of it sure can. I'm sure there is plenty of evidence of physical difference betweeen races, and there are reasonable ways to use those scientific results - and there are racist ways of using them. Doesn't change that

> Second, the author didn't argue there are differences between genders or sexes that make one unsuitable for a given task.

Wow I read the whole thing (which is rare) and that was what really jumped out. I wonder what I misunderstood.

The memo wrote that women generally have a harder time leading. His cited sources don't back that up. How is it a misrepresentation to say he said women generally are not as good at certain roles, like leading? That statement is word for word in the memo,

"This leads to women generally having a harder time negotiating salary, asking for raises, speaking up, and leading."