Say it is purely personal preference: 50% of people can work well in open offices, and 50% of people cannot. Even if that were the case (which I highly doubt), that would still be a solid argument for closed offices. Why? Because while people who can work well in open offices can easily adjust their closed office to suit their temperament (e.g. by blaring loud German marching music), people who cannot work well in open offices have no recourse. Headphones are the recommended strategy, but in my experience they still lead to a decrease in productivity and are generally uncomfortable when worn for an entire day. Further, they do not block out the visual distractions of people walking back and forth, etc. They also do nothing for the feeling of lack of privacy, which for me personally is one of the most egregious aspects of an open plan office.

I think that among programmers especially, the proportion of people who cannot work at peak productivity in an open plan office is much higher than 50%, but even if it were only 30% that would still be a strong argument for closed offices.