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Since electrostatic discharge (ESD) protection devices comprise the “front end,” or interface between an integrated circuit and the system bus, they may be driven into nonlinearity when the system operates in a high-power microwave (HPM) environment. We have experimentally studied HPM effects in CMOS-based ESD devices, and showed that asymmetry in the large-signal responses of NMOS and PMOS ESD protection devices drives spurious bias shifts in the circuit. These shifts have been shown elsewhere to produce serious secondary effects such as increased power consumption, state errors and instability. Using an in-house developed physics-based drift-diffusion simulator, we present some fundamental imbalances in the NMOS and PMOS device behavior and performance.