This whole conversation is pretty silly, given than no one seems to know anything aside of what is publicized so far.
But here is a daring theory:
Maybe the low headroom, i.e. propensity to distort, is intentional?
Maybe the goal was to immitate some type of overdrive behavior that was deemed by the designers to "sound attractive"?
Maybe this was a deliberate departure from Neumann's usual 'clean'-philosophy, into the terrain which the Neumann/Sennheiser management by now must be painfully aware of:
Users want sounds that connect emotionally. A sound which, judging from the countless responses on this and the Neumann forum, customers largely don't believe they are getting from current "clean" products...?
Then, of course, the big question remains: can you engineer that kind of emotional attraction into a (prosumer) mic design through emulation? Or do you actually need a characterful mic with characterful components to begin with?