our circuit has noted that we have “no opinion on whether the habitual residence of a child who lacks cognizance of his or her surroundings should be determined by considering the subjective intentions of his or her parents.” Robert, 507 F.3d at 992 n.4. By “subjective intentions,” we mean the parents’ last “settled mutual intent” for where their child would live. Gitter v. Gitter, 396 F.3d 124, 133, 135 (2d Cir. 2005) (internal quotation marks and citation omitted); see also Nicolson v. Pappalardo, 605 F.3d 100, 104 (1st Cir. 2010); Feder v. Evans-Feder, 63 F.3d 217, 224 (3d Cir. 1995). The district court noted the reliance by courts on the shared parental intent standard in cases concerning especially young children. See, e.g., Redmond v. Redmond, 724 F.3d 729, 746 (7th Cir. 2013) (<HOLDING>) (quoting Holder, 392 F.3d at 1016-17).
recognizing that claim meaning will sometimes be readily apparent even to lay judges and that claim construction in such cases involves little more than the application of the widely accepted meaning of commonly understood words recognizing  parental intent acts as a surrogate in cases involving very young children for whom the concept of acclimatization has little meaning holding the prospective adoptive father of surrogate children did not comply with the interstate compact on the placement of children holding that taking care of three young children one of whom suffered from a serious medical condition and being needed at work were purely personal circumstances not exceptional reasons for release holding that the clear and convincing standard provides appropriate due process in cases involving parental rights