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We utilize low-frequency noise measurements to examine the sub-threshold voltage (sub-VTH) operation of highly scaled devices. We find that the sub-VTH low-frequency noise is dominated by random telegraph noise (RTN). The RTN is exacerbated both by channel dimension scaling and reducing the gate overdrive into the sub-VTH regime. These large RTN fluctuations greatly impact circuit variability and represent a troubling obstacle that must be solved if sub-VTH operation is to become a viable solution for low-power applications.