There is experimental evidence that ultrasoft X rays (0.1–5 keV) show a higher biological effectiveness than high-energy photons. Similar to high-LET radiation, this is attributed to a rather localized dose distribution associated with a considerably smaller range of secondary electrons, which results in an increasing yield of double-strand breaks (DSBs) and potentially more complex lesions. We previously reported on the application of the Giant LOop Binary LEsion (GLOBLE) model to ultrasoft X rays, in which experimental values of the relative biological effectiveness (RBE) for DSB induction were used to show that this increasing DSB yield was sufficient to explain the enhanced effectiveness in the cell inactivation potential of ultrasoft X rays. Complementary to GLOBLE, we report here on a modeling approach to predict the increased DSB yield of ultrasoft X rays on the basis of amorphous track structure formed by secondary electrons, which was derived from Monte Carlo track structure simulations. This procedure is associated with increased production of single-strand break (SSB) clusters, which are caused by the highly localized energy deposition pattern induced by low-energy photons. From this, the RBE of ultrasoft X rays can be determined and compared to experimental data, showing that the inhomogeneity of the energy deposition pattern represents the key variable to describe the increased biological effectiveness of ultrasoft X rays. Thus, this work demonstrates an extended applicability of the amorphous track structure concept and tests its limits with respect to its predictive power. The employed model mechanism offers a possible explanation for how the cellular response to ultrasoft X rays is directly linked to the energy deposition properties on the nanometric scale.