The new theory suggests that life on Earth-type planets is likely.

The term earth-type planets mean planets that have similar structures to Earth. They might have solid cores.

But the water layer can cover the entire rocky world. These kinds of planets are called water worlds. 

Or they might be dry. That means there could be hydrocarbon oceans but no water on those planets. Those rocky planets are like the giant Titan moon. There could be giant oceans that formed of hydrocarbons. 

The hostile-looking planets can host the Black Swan-versions of lifeforms. Black Swan means a possible but extremely extraordinary case. And maybe, some extraordinary planet hosts very extraordinary but primitive life forms. 

There is Earth type of planets that are covered with lava oceans. And that kind of lava planet is the only planet that cannot host alien life. Or there is the possibility that in the atmosphere of those hellish planets can hover organisms that use the atmospheric temperature of that planet as an energy source. 

Those life forms could be rather DNA or RNA-controlled miniature crystals than bacteria. There is the possibility that those bacteria are multiplying very fast, and even if a single organism could live only minutes that entirety can be stable. But that kind of theoretical lifeform is possible but very extraordinary. So those theoretical extreme primitive alien proteobacteria are like the "Black Swan" phenomenon of lifeforms. 

So water worlds and super-earths can also be determined as Earth-type planets. Intelligent lifeforms are not the same thing as lifeforms. The lifeforms of those rocky worlds might be different than we can even imagine. And before we can send probes to those distant rocky planets or find lifeforms from some gas giants' icy moons, we can only make hypotheses and theories about the shape of extraterrestrial lifeforms. 

And there is no place where we can close things like primitive lifeforms straight out from possibilities. Those hypothetical lifeforms can live in the depth of the ocean that covers the super earth. And even if the super earth orbits very close to the red dwarf there is a possibility that the super-Earth's massive gravitation keeps the water liquid. So along with water vapor, the planet could be more suitable for fish-type alien organisms than people normally think. 

The surface of the water and atmosphere can be boiling. But deep inside the ocean, the temperature can be more comfortable. Because the planet could orbit the M-type red dwarf there is a possibility that the hypothetical planet is locked. And the nightside, along with the monsoon stabilizes the atmosphere's temperature. Also, water flow between night and dayside of a locked planet could make the ocean of that kind of planet very comfortable. And the atmosphere would be more gentle than we even thought. 

Could a planet with hot ice, Gliese 436b host life? 

Hypothetical lifeform of the most extraordinary exoplanet, Gliese 436b, "the world of burning ice". 

But if we are thinking about the super earth and especially super-earth where the massive gravitation makes water impossible to vapor. There is the possibility that the exoplanets that "hot ice" covers can host hypothetical lifeforms that are similar to tapeworms on Earth. 

We can ask: "could that kind of planet host any kind of lifeform"? The planet Gliese 436b is the kind of planet where massive gravitation causes the effect, where the planet's entire surface is covered by hot ice. The planet's surface is about 712 Kelvin, and the name of that planet is "planet with burning ice". The massive gravitation makes the water stay in the form of ice in very hot conditions. 

The Gliese 436 b is the strangest exoplanet ever found. And that means other exoplanets are less extreme. But can that kind of super strange exoplanet have living habitats? 

The answer is "yes". That Neptune size exoplanet can have tapeworm-type alien worms that could live in that hot ice. Those 2-dimensional alien creatures can dig tunnels in that hot ice. 

And they might have similar electric cells as an electric eel. Those cells can turn the ice or water molecules into oxygen and hydrogen. So those hypothetical lifeforms can be a little bit similar to tapeworms on the Earth. That thing came to my mind when I read about the new theory that life is more common in the universe than we ever imagine. 

https://futurism.com/the-strangest-exoplanet-ever

https://scitechdaily.com/new-theory-suggests-that-the-origin-of-life-on-earth-like-planets-is-likely/

https://en.wikipedia.org/wiki/Gliese_436_b