Stated another way, the sperm and the ovum are specialized tissues of life. The individual they become is a complete entity of life. I mean after all, it's not even recognizable during the first few weeks of development. Formation is not, by itself, an adequate indication of the presence or absence of life. Here again, the Court was beyond its depth.
Canyons form, crystals form, stalactites form and so on.
But each of these formations are the result of a process, such as erosion, crystallization, or mineralization. So is life a process. Whatever form it takes is incidental to and a consequence of that process. Nothing happens in the absence of process. The young woman was silent, nodding, thinking.