On March 1st, PL files that reply/opposition to the motion to dismiss.
It cites a bunch of cases in support of its argument! They seem quite convincing - there's some state courts holding that state courts can decide international airline accidents. (See pages 4 and 5). https://storage.courtlistener.com/recap/gov.uscourts.nysd.575368/gov.uscourts.nysd.575368.21.0.pdf