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we were lead to believe she died in X2, but true X-fans knew she would be back for the 3rd one. Xavier x-plains (haha) that Jean wrapped herself in a telekinetic coccoon that protected her. then she fell into her dormant split personality and became the Phoenix
Well that is pretty close to what happened in the comics too if recall but I think it was a real cacoon and well the Pheonix outfit just rocks in my book.