Windows "blocks" the serial/rs-232 port on start-up?

I'm working on a dll for Omnipass, wich will allow the user to login to Windows via a device connected to the COM port.
The dll works perfectly when testing it through a test-app, but when I try to test it with Omnipass (restart the computer and check the log in screen), something goes wrong.
Omnipass finds the dll, tries to open a connection but fails. According to my error log, GetLastError() generates "Access is denied."

Is it possible that Windows occupies the COM port on startup to check for other connected devices and such?

Thanks in advance.
- Daniel
I tried adding both "/fastdetect" and "/NoSerialMice" to boot.ini without success.
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