We present analysis of about one hundred bipolar structures of positive polarity identified in ten quasi-perpendicular crossings of the Earth's bow shock by the Magnetospheric Multiscale spacecraft. The bipolar structures have amplitudes up to a few tenths of local electron temperature, spatial scales of a few local Debye lengths, and plasma frame speeds of the order of local ion-acoustic speed. We argue that the bipolar structures of positive polarity are slow electron holes, rather than ion-acoustic solitons. The electron holes are typically above the transverse instability threshold, which we argue is due to high values of the ratio ωpe/ωce between electron plasma and cyclotron frequencies. We speculate that the transverse instability can strongly limit the lifetime of the electron holes, whose amplitude is above a certain threshold, which is only a few mV/m in the Earth's bow shock. We suggest that electron surfing acceleration by large-amplitude electron holes reported in numerical simulations of high-Mach number shocks might not be as efficient in realistic shocks, because the transverse instability strongly limits the lifetime of large-amplitude electron holes at ωpe/ωce values typical of collisionless shocks in nature.