The subtle nigoda are in water, land and sky without constraint: there is no point of the universe, from the seventh hell to Siddhaśilā's rim, that is not full of them.
The Ṣaṭkhaṇḍāgama places the subtle nigoda in water, on land and in the sky without material or spatial constraint — which is to say everywhere. They cannot be seen, cut, burned or crushed; no fire reaches them and no weapon; they neither harm nor are harmed by anything gross. Every space-point of the Loka is their address, inside the trasanāḍī and outside it, where nothing else can live.
This is the sense in which a Jain teacher says the universe is full of life: not that living things are common, but that there is nowhere, at all, that is not occupied. The gross nigoda, by contrast, live only where a body can be.
Nigoda: the smallest body, the most souls — Sūkṣma nigoda highlighted