Could be. First you would do well to check on the possibility that they are linear plating blisters. Looking at the full reverse of your coin it appears that there are vertical lines coming down from the last half of STATES all the way through the bottom of the memorial. If you have vertical plating blisters on the coin that would then be more likely what you are seeing in the bays than a DDR. Interesting coin and worth looking closely at to see if you can work it out.
If you look above and below the column, you can also see die scratches through the bays and above and below the building on the whole building. (if you are seeing the lines on the centers of the bays)
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