so would not be appropriate in this case. Cf. Def.'s Corrected Resp. in Opp’n to Pl.'s Mot. for J. Upon the Agency R„ ECF No. 41 ("Def.'s Br.”) at 20-23 (arguing that the court should decline to reach the merits of AHSTAC's contention in this regard because AHSTAC failed to make this argument before the agency in the first instance); 28 U.S.C. § 2637(d) (”[T]he Court of International Trade shall, where appropriate, require the exhaustion of administrative remedies.”) (emphasis added); Blue Field (Sichuan) Food Indus. Co. v. United States, - CIT -, 949 F.Supp.2d 1311, 1321 (2013) (“This court has discretion to determine when it will require the exhaustion of administrative remedies.”) (citing 28 U.S.C. § 2637(d)); Itochu Bldg. Prods, v. United States, 733 F.3d 1140, 1145 (Fed.Cir.2013) (<HOLDING>) (citation omitted). 17 . Importantly,
holding that a courts authority to require exhaustion of administrative remedies in actions brought under the apa is limited when neither the statute nor agency rules specifically mandate exhaustion as a prerequisite to judicial review recognizing that exhaustion of state administrative remedies is not a prerequisite to bringing a  1983 action holding that requiring exhaustion of administrative remedies is appropriate where doing so can protect administrative agency authority and promote judicial efficiency holding that courts have consistently required exhaustion of administrative remedies under foia holding that proper exhaustion of administrative remedies is necessary under section 1997ea