I don't think so. I think he/she wanted a simple one-line answer to a question that does not seem quite so simple.

While the Linux swap does have a structure, you cant use it to store files, or even view file, in fact, you cant even mount it on a directory at all, which is why it isn't a file system in the traditional sense.

Almost everything in computer has some kind of structure.

http://www.answers.com/main/ntquery?...+system&gwp=13

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http://en.wikibooks.org/wiki/Guide_t...stems_and_Swap

: ... Some disks are also used for swap, which supplies a temporary storage space for data in memory, when memory is full. Though "swap" resides on a disk, it is not actually a filesystem.
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