  The present equilibrium formulation of thermodynamics for black holes has
several drawbacks, such as assuming the same temperature for black hole and
heat bath. Recently the author formulated non-equilibrium thermodynamics for
glassy systems. This approach is applied to black holes, with the cosmic
background temperature being the bath temperature, and the Hawking temperature
the internal temperature. Both Hawking evaporation and absorption of background
radiation are taken into account.
  It is argued that black holes did not form in the very early universe.
