Another thing is where are all those cells. Are they gonna be swimming around in the dilute-ass ocean?
(Y'all should know I think the ocean of ocean worlds is the WORST place to look for life. Big. Dilute. Boring.)
Life loves interfaces. Ice-ocean interface, ice-bottom interface, brinicles, cold-seeps (up or down), and especially micropockets in ice.
(I'll be posting something exciting about micropockets in a few weeks. Stay tuned.)