These aren't certificates signed by a CA that's trusted by most browsers - they're self-signed certificates (signed by the appliance) that are trusted within the organization using the Barracuda hardware by provisioning employee browsers to accept the CA.
If you were to extract the private key and use it to sign certificates elsewhere, you'd get the same warning as though you generated a random certificate and used it; the key is only useful within the organization that trusts it.
However, if an organization were able to get a widely-trusted MitM cert (such as this one http://www.theregister.co.uk/2012/02/09/tustwave_disavows_mi... or this one http://ssl.entrust.net/blog/?p=1696 ) and deployed it on their Barracuda, it could likely be extracted by someone with root-level access.
It wouldn't surprise me to see some "loose nukes" arise out of Barracuda's utterly irresponsible behavior here.
Generally if you're targeting a specific organization, that's what you care about, anyway. You're not hacking into random companies to build a botnet; you're going after a specific organization to gain some economic or intelligence/military benefit.
I don't know what important organizations use Barracuda, though. It's generally SME-focused. Might be some interesting law firms and other organizations with sensitive data belonging to larger organizations, though.
1. Unconstrained, like the Trustwave and Turktrust examples. These can be used to MitM any domain, with a very few exceptions like Chrome talking to Gmail. This is the normal kind of subCA.
2. Name-constrained sub-CAs such as described here https://groups.google.com/forum/?fromgroups=#!topic/mozilla.... These are very new. They aresupposed to be for organizations (say example.com) that want to issue their certs for www.example.com, intranet.corp.example.com, and so on without using a wildcard cert or paying extra for every single cert.
Neverheless, these private keys can sign MitM certs for any domain, however, whether or not it's valid is in the mind of the client application. Recent versions of the the three major browsers should in theory only accept them for names that sub-CA is approved for. But few if any non-browser SSL/TLS clients recognize these name constraints, so it represents full MitM capable attacker to those clients. Of course, there are a lot of TLS clients that don't validate or even check the subject name on the server cert at all, so many of these apps are pwned anyway.
Or am I missing something?