You might find a statistical analysis of "which way up PCGS or the other TPGs slab a coin" to be especially interesting for coins where the question "which side is the obverse" is debated or ambiguous - such as the Oregon Trail half dollar.
I believe in most cases, PCGS has an official "this is the obverse side" decision pre-made for every coin they slab (which may or may not agree with that nation's official definitions of obverse and reverse) - and it's that PCGS-defined obverse side that comes "face up" every time, unless the customer requests otherwise.
There are series for which this makes little to no sense - such as most of the modern British and British Empire/Commonwealth coinages (Australia, Canada, South Africa, India, etc) - within which almost all the information needed to actually identify the coin properly (country, denomination, date and often mintmark) is located on the reverse, not the obverse. Yet the "obverse rules" rule continues to apply.
I once knew a local dealer here in Australia who insisted on putting all his coins for sale in 2x2s with the writing on the 2x2 always on the "obverse" side - even though it made for some awkward flip-flipping whenever you wanted to compare the information on the coin with the information written on the 2x2, given that a large percentage of his coins were Australian or British/Empire/Commonwealth. I asked him why he did it that way since you can't actually see the important information while it's face-up, and his response was "Oh, I never really thought about it like that". To him, the obverse was the front, end of thought process about it. The slabbing companies seem to have had much the same thought process.
Don't say "infinitely" when you mean "very"; otherwise, you'll have no word left when you want to talk about something really infinite. - C. S. Lewis