OPINION

POGUE, Senior Judge:

This action returns to court following redetermination on remand. Prior to remand, in its initial decision, the U.S. Department of Commerce ("Commerce") determined that Plaintiff, Ceramark Technology, Inc. ("Ceramark"), had circumvented the antidumping duty order on small diameter graphite electrodes ("SDGE") from the People's Republic of China ("PRC").1 Ceramark challenged this decision as not in accordance with law and unsupported by a reasonable reading of the record evidence.2 The court agreed in part, and remanded, ordering Commerce to consider important aspects of the record that weighed against Commerce's determination. Ceramark, Tech., Inc. v. United States, ___ CIT ___, 11 F.Supp.3d 1317, 1323-25 (2014). During the remand, however, Ceramark did not file comments on Commerce's draft redetermination. Final Results of Redetermination Pursuant to Ct. Remand, ECF Nos. 50-1 (conf. ver.) & 51-1 (pub. ver.) ("Final Redetermination"), at 5. In that redetermination, Commerce again concluded that Plaintiff had circumvented the SDGE Order. Id. at 1. Defendant and Defendant-Intervenors now seek dismissal for failure to exhaust administrative remedies.3 Plaintiff argues that exhaustion is not required here because further comment would have been futile.4

Contrary to Plaintiff's arguments, as explained below, exhaustion was appropriate, not futile, because Commerce's remand redetermination involved new factual findings and a re-weighing of all the record evidence upon which the agency's decision was based. Therefore, this action is dismissed for failure to exhaust administrative remedies.

BACKGROUND

This controversy stems from an antidumping duty order on SDGE from the PRC. That order covers "all [SDGE] of any length, whether or not finished, of a kind used in furnaces, with a nominal or actual diameter of 400 millimeters (16 inches) or less ..." SDGE Order, 74 Fed. Reg. at 8775.5 Subsequently, Commerce determined, pursuant to § 781(c) of the Tariff Act of 1930, as amended, 19 U.S.C. § 1677j(c) (2012),6 that 17-inch graphite electrodes constituted a circumventing minor alteration of the order. Final Determination, 78 Fed.Reg. at 56,864-65.

Plaintiff, an importer of 17-inch graphite electrodes, challenged Commerce's minor alteration determination, Compl., ECF No. 9 at ¶ 2, as not in accordance with law and unsupported by substantial evidence on the record. Rule 56.2 Mem., ECF Nos. 24-1 (conf. ver.) & 25-1 (pub. ver.). The court agreed in part and remanded because the agency had not reasonably considered: (1) the prior commercial availability of 17-inch graphite electrodes; (2) the importance of diameter as a defining characteristic of graphite electrodes; and (3) the decision made by petitioners, Commerce, and the ITC to exclude 17-inch graphite electrodes from the original antidumping duty order. Ceramark, ___ CIT at ___, 11 F.Supp.3d at 1323-25.

On remand, Commerce re-weighed all the record evidence, including the previously unconsidered facts, and found that the evidence emphasized by the court did not so detract from the substantiality of the evidence as to dictate a different outcome. The agency again found that 17-inch graphite electrodes constituted a circumventing minor alteration. Draft Remand Redetermination, ECF No. 72-1 ("Draft Redetermination"), at 4-9. Commerce circulated its draft redetermination, requesting comments. See Remand Admin. Rec. Index, ECF No. 52, at 1 (Public Document 2 (letter from Commerce to interested parties setting deadline for comments)). Plaintiff, despite participating fully in prior administrative and judicial proceedings, did not respond. Final Redetermination, ECF No. 51-1, at 5.7 Commerce then filed its final redetermination, substantially the same as the draft, finding "no reason to alter" its prior circumvention determination. Final Redetermination, ECF No. 51-1, at 1.

Defendant and Defendant-Intervenors now seek dismissal for failure to exhaust administrative remedies. Def.'s Resp., ECF No. 61, at 4-6; Def.'s Surreply, ECF No. 71; Def.-Intervenors' Resp., ECF No. 62, at 11-12; Def.-Intervenors' Surreply, ECF No. 69. In response, Plaintiff argues that exhaustion of administrative remedies is not required because the futility exception applies. Pl.'s Reply, ECF No. 68.

DISCUSSION

I. Exhaustion of Administrative Remedies

Plaintiffs, "where appropriate," are required to exhaust administrative remedies before seeking judicial relief. 28 U.S.C. § 2637(d). This means that, with limited exception, "no one is entitled to judicial relief for a supposed or threatened injury until the prescribed administrative remedy has been exhausted." Sandvik Steel Co. v. United States, 164 F.3d 596, 599 (Fed.Cir.1998) (quoting McKart v. United States, 395 U.S. 185, 193, 89 S.Ct. 1657, 23 L.Ed.2d 194 (1969)).

Here, Ceramark has not exhausted its administrative remedies because it did not comment on Commerce's draft during the remand proceeding. Final Redetermination, ECF No. 51-1, at 5; see also Pl.'s Reply, ECF No. 68, at 1 (arguing that exhaustion of remedies not appropriate here).

II. The Futility Exception

Failure to exhaust is not per se fatal to Ceramark's challenge — exhaustion is a practical, not absolutist, doctrine. It accommodates exceptions. Exhaustion is meant to "protect[] administrative agency authority," McCarthy v. Madigan, 503 U.S. 140, 145, 112 S.Ct. 1081, 117 L.Ed.2d 291 (1992), by "ensur[ing] Commerce has the opportunity to consider arguments during agency proceedings, and before a judge intervenes on appeal." Blue Field (Sichuan) Food Indus. Co. v. United States, ___ CIT ___, 949 F.Supp.2d 1311, 1322 (2013).8 Further, exhaustion "promot[es] judicial efficiency," McCarthy, 503 U.S. at 145, 112 S.Ct. 1081, by "promoting development of an agency record that is adequate for later court review and by giving an agency a full opportunity to correct errors and thereby narrow or even eliminate disputes needing judicial resolution," Itochu Bldg. Products v. United States, 733 F.3d 1140, 1145 (Fed.Cir.2013) (citing McCarthy, 503 U.S. at 145-46, 112 S.Ct. 1081). However, "where the obvious result would be a plain miscarriage of justice," exhaustion is not required. Hormel v. Helvering, 312 U.S. 552, 558, 61 S.Ct. 719, 85 L.Ed. 1037 (1941). Where exhaustion serves no purpose, when further comment would be futile — that is, "a useless formality," Yangzhou Bestpak Gifts & Crafts Co. v. United States, 716 F.3d 1370, 1381 (Fed.Cir.2013) (citation omitted), or involving "obviously useless motions in order to preserve [parties'] rights," Corus Staal BV v. United States, 502 F.3d 1370, 1379 (Fed.Cir.2007) (quotation marks and citations omitted) — exhaustion is not required.

Ceramark argues that there is "no practical reason to apply the exhaustion doctrine" here, because further comment on its part during the remand proceedings would have been futile. Pl.'s Reply, ECF No. 68, at 10. Ceramark claims that it had already repeatedly presented all its arguments to Commerce, Commerce had repeatedly rejected those arguments, and "there is nothing in the record or in Commerce's Redetermination to suggest that Ceramark's arguments would have been considered any differently had Ceramark presented them again." Id., at 6. Ceramark considers it "disingenuous for Commerce to urge this Court to apply the exhaustion doctrine, since Commerce itself stated that Ceramark's arguments were before the agency on remand and were, in fact considered and, as usual, rejected." Id. at 5-6.

It is possible, indeed likely, that if Ceramark had simply re-submitted its previous comments, Commerce would not have changed its position. This is because Commerce was already considering these same comments on remand, in accordance with Ceramark, ___ CIT at ___, 11 F.Supp.3d at 1323-25. See Draft Redetermination, ECF No. 72-1, at 5-6, 8-9. But repetition is not what the Plaintiff was required to do here. Rather, Plaintiff was required to comment on new factual findings, and the resultant new balance of evidence, that Commerce undertook specifically for this redetermination.9 The best indication of this is Plaintiff's own comments on the redetermination filed with this Court, which offered additional, fact-based arguments tailored to the remand.10 While Commerce still might not have agreed with Ceramark's arguments on remand, the "mere fact that an adverse decision may have been likely does not excuse a party from a statutory or regulatory requirement that it exhaust administrative remedies." Corus Staal, 502 F.3d at 1379.11 Providing comments on remand would have, at the very least, provided "the agency an opportunity to set forth its position in a manner that would facilitate judicial review." Id. at 1380.12 Certainly the court's review would have benefited had Commerce had the opportunity to consider whether its new factual findings, reconsideration, and resultant redetermination were based on a reasonable reading of the entire record.

CONCLUSION

Because Ceramark did not provide comments to Commerce during remand proceedings, Ceramark did not exhaust its administrative remedies. Because filing comments would not have been a useless formality, the futility exception does not apply. Accordingly, this action is dismissed for failure to exhaust administrative remedies.

IT IS SO ORDERED.