I believe it's an x.509v3 limitation and not specific to openssl.
After getting Viktor's hint I did a little research and found that the 
limitation is set at 2^14.

Ron

Steffen DETTMER wrote:
> 
> * Victor Duchovni wrote:
>> The SSL/TLS record layer has a maximum record size, a
>> certificate probably needs to fit into one record, so if your
>> 500+ domains generate a certificate that is larger than ~16K
>> bytes, you may be out of luck.
> 
> (I just ask for curiosity, not because I have any problem with that!)
> Does this mean that OpenSSL has a compiled-in certificate size
> limitation and to increase that it would be required to replace
> the libs on the systems needing to support bigger certificates?
> 
> oki,
> 
> Steffen
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