Can you provide the entire letter? That might make it easier for us to provide the right answer.
However from the short text you have provided, what this says to me is that the appeal you sent does not argue that you were incorrectly refused. In other words, you know you were correctly refused and are trying to use other reasons in your appeal argument that aren't relevant to your refusal reason.
When someone sends an appeal letter, what you are typically trying to do is argue that you were incorrectly refused by CIC by listing the specific reasons why CIC refused you - and then providing evidence or information to counter these statements and prove the specific refusal reasons were wrong. It sounds like your appeal letter did not do this. In other words, you did not disagree or dispute that the reasons why CIC refused you were correct.
For example, let's say you were refused for failing to meet the residency obligation. When you appealed, let's pretend that you agreed that you didn't meet RO - but then tried to argue that the fact you didn't meet RO should be overlooked because you had strong ties to Canada. This would be an example: "It does not appear to be in dispute that the refusal is legally valid in this case."
At least this is what I think. Hope it helps.
