Doubtfull. It probably using normal volatile ram of some sort, which is why the battery dieing causes it to forget everything it ever knew. This always seemed like an amazingly bad design decision and is probably based on flash prices at least 8 years ago. Many current PocketPC's include a flash disk, but this usualy shows up seperatly from the main "drive" which is ROM copied into memory. Another side effect of this is that the thing can never turn itself off, so the batteries are empty (and it has forgotten everything it ever knew) in just a few weeks no matter what.
This could have all changed with the most recent Wince revision, I havn't been keeping up.
Matthew