Using cn or ou for groups and containers

[<fuser9bb@hotpop.com>]

I use groupOfUniqueNames for group membership. At times, I need to create a
container that contains groups under it, such as:

ou=Groups
cn=Group1,ou=Groups
cn=Group2,ou=Groups
cn=Subgroup1,cn=Group2,ou=Groups

In this case I would not place any members in cn=Group2. (Although I suppose
this may happen in some special circumstances if an application wants it,
for example to define "default" users and the subgroups define special
accounts.)

In this case do most people create Group2 as a groupOfUniqueNames (or
groupOfNames) and use a cn value as the RDN, or would you create Group2 as a
organizationalUnit and use an ou as the RDN?