how can the pa sos “not certify”??
Because it is tied up in court.
See this timeline of Florida 2000 to see how the SoS was prevented from certifying for 12 days beyond the state's legal certification deadline.
The election court challenges can't even begin until it is first certified. The longer the certification is delayed, the shorter the period for court challenges before bumping up against the safe harbor date for the Electoral College.
-PJ