In his report, the Information Commissioner deals with this section in considerable detail. For example, he refers to cases where the number of requests submitted by the requester is very large. He states that, of itself, the fact that a requester has submitted a large number of requests does not indicate that any of them are frivolous or vexatious. He further states that, apart from any other consideration, the question of what constitutes a large number of requests is so subjective as to be of little value in practice in determining whether section 10(1)(e) might apply. In addition, he states that the number of requests received by a public body, both generally or from any one requester, must depend in part on its attitude to the release of information. He gives the example of a public body routinely resisting requests for information which perhaps other public bodies would release administratively and states that it may end up receiving a large number of FOI requests. He goes on to state that it could hardly be correct that its subsequent difficulties in processing these requests should be laid at the door of the requesters who are merely seeking to exercise their statutory rights. In saying this he is not suggesting that the difficulties which the Department has experienced – a case is referred to earlier in the report – with Mr. A.B.W. are of its own making but is merely making the point to show the difficulties in refusing requests solely because the requester has made a large number of requests.