I had the same 'out of memory' error on BES 4.0 for Exchange. Simply stopping and restarting the MDS service fixes that issue though - no downtime for your BES.
But yes, it is a memory leak. I'm not sure if its known though. I've been running BES 4.0 for about three weeks now and only have seen it once.
I only have about 10 users on the BES 4.0 server (in test; 3.6 in production), and only about 4 need MDS, so I disabled it for the others at the same time I first saw the error.
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