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We show that any memory-constrained, first-order algorithm which minimizes $d$-dimensional, $1$-Lipschitz convex functions over the unit ball to $1/\mathrm{poly}(d)$ accuracy using at most $d^{1.25 - \delta}$ bits of memory must make at least $\Omega(d^{1 + (4/3)\delta})$ first-order queries (for any constant $\delta \in [0, 1/4]$). Consequently, the performance of such memory-constrained algorithms are a polynomial factor worse than the optimal $\tilde{O}(d)$ query bound for this problem obtained by cutting plane methods that use $\tilde{O}(d^2)$ memory. This resolves one of the open problems in the COLT 2019 open problem publication of Woodworth and Srebro.