Yes. I had an app rejected for the same reason. Just appeal, and explain your position. In my case, I made a viewer for Microsoft Access databases. Apple kept

Yes. I had an app rejected for the same reason. Just appeal, and explain your position. In my case, I made a viewer for Microsoft Access databases. Apple kept complaining that there was no way to create databases on the phone. After a few back and forths someone realised that a viewer doesn't need to create files, and the app was accepted.