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Comma Characters

In Clause on page 261, the /COMMA/ is referred to being
defined in clause 36.

In this section, both a positive and negative comma are defined.
I believe that in 1 GE devices, usually only positive commas were
recognized.  Is this enough to be 1 GE and 10 GE compliant?  

In a IPG over 20 bytes, both commas will probably exist.  In 
sustained minimum IPG, the positive comma occurrence may be random.
Do positive commas occur often enough?

Maybe this detail should be stated?

/Brian Cruikshank