Grace was the first choice to play the lead in the film - about a soldier who wakes up in the body of an unknown commuter and must relive a horrific train bombing to catch the mastermind behind the disaster.
The project was initially scheduled to begin shooting in 2007.
However, movie executives at Vendome Pictures and the Mark Gordon Company have taken over the film from Universal; and Gyllenhaal is in negotiations to replace Grace, according to Daily Variety.
Production is scheduled to begin in 2010.