So how about life in the Jovian atmosphere?
Floating gasbags, giant jellyfish, delta wing hunters, and more!
Since most of the exoplanets we currently know are giant Jupiter types, and at least some of them do not orbit practically in their star's photosphere, studying whether they could have life in their atmospheres does have merit.
The famous Sagan and Salpeter paper online here:
http://adsabs.harvard.edu/cgi-bin/nph-bib_query?bibcode=1976ApJS...32..737S&db_key=AST
http://www.daviddarling.info/encyclopedia/J/Jupiterlife.html
http://www.windows.ucar.edu/tour/link=/earth/Life/J_environment.html
http://www.google.com/url?sa=U&start=2&q=http://www.as.utexas.edu/astronomy/education/spring05/evans/lectures/309l_lec12_print.pdf&e=9797
