all the allegations in the complaint are true even if doubtful in fact.’ ” Corus Staal BV v. United States, 515 F.Supp.2d 1337, 1345 (CIT 2007) (quoting Bell Atl. Corp. v. Twombly, 127 S.Ct. 1955, 1959 (2007)). Canex argues that the Government failed to exhaust administrative remedies by commencing this action for liquidated damages without engaging in mitigation proceedings. Under 19 C.F.R. § 172.1(b) and 19 U.S.C. § 1623(c), a principal or surety can petition Customs for relief from payment of liquidated damages through such proceedings. See United States v. Cocoa Berkau, Inc., 990 F.2d 610, 615 (Fed. Cir. 1993). Mitigation proceedings are voluntary and informal, and relief is granted at the discretion of Customs. United States v. Ataka Am., Inc., 826 F. Supp. 495, 502 (CIT 1993) (<HOLDING>); Cocoa Berkau, 990 F.2d at 615 (“[T]he
recognizing that liquidated damages under the flsa  are compensation not a penalty or punishment  holding that a mitigation proceeding for liquidated damages under 19 usc  1623cis voluntary holding that because liquidated damages under the adea are punitive in nature a jurys award of state punitive damages and adea liquidated damages constitutes a double recovery and therefore reducing the total recovery by the amount of the liquidated damages award holding that liquidated damages under the adea are intended to punish and deter while contrasting them to the legislative purpose of liquidated damages under the fsla holding that liquidated damages under fair labor standards act constitutes compensation for the retention of a workmans pay which might result in damages too obscure and difficult of proof for estimate other than by liquidated damages