Hope it helps for other people in same water.
PhD from US, 3 first Author paper but less than 20 citations, which was the basis for the denial (original and REF) by IO375. Self-prep, but REF prepared by lawyer, who suggesting re-apply, but I decided to appeal at last moment ($1600 extra) in July. Emphasis on novel/cutting edge/important but overlooked/research area to explain low citation also backed up by 5 references from RFE. Approved in 2 months: lawyer believes it never reaches AAO but approved within NSC during motion of reopen. Good luck.