In linear wave-particle interaction models, the coupling between cold electrons and microwaves with frequency equal to twice the electron gyrofrequency is so weak that the ionization of a significant number of neutral hydrogen atoms would seem impossible in practical applications. However, the non-linear interaction of a cold electron with the wave is very large if the electron becomes trapped near resonance in a shallow, static magnetic well. A model has been developed to describe the breakdown of a neutral gas when these non-linear interactions are considered, and it is in reasonable agreement with the limited amount of available experimental data. For gas pressures that are too large, electron-neutral collisions inhibit the non-linear interaction and prevent breakdown. For gas pressures that are too low, the growth rate of the free electron population is limited because electrons capable of causing ionization are lost before suffering a collision with a neutral. Quantitative growth rate predictions are presented for stellarators, and formulae for rough estimates are given.