the issue of the abduction of children from the united states to brazil has been raised by obama, secretary of state hillary clinton, the united states house of representatives and other u.s. officials and major media. as of december 2009, there are 66 american children that have been taken by one of their parents to live in brazil. while brazil is obligated under the hague convention on the civil aspects of international child abduction to return every child to the u.s., it has not. under the treaty, one parent cannot flee the legal jurisdiction where the child resides – "his habitual residence" – to shop for a more favorable court venue in another country to contest for custody.