To establish a domicile of choice, it is necessary to have a clear factual base in one state and that must be accompanied by an "animus semper manendi" (). Although it is not so difficult to produce evidence that an individual has established a home in a state, it is very difficult to prove that someone has no intention of ever establishing a home in another state. The test for habitual residence is less demanding. The court focuses on the past experience of the individual and not so much on future intention.