He only needs Juggernaut if I use my Impale - Impact spec, in fact I have yet to see a Barb that can beat me consistently without using Juggernaut against that spec. Most Barbs I play against will try to counter-spec after losing a few rounds with Juggernaut, at which point I will go back to Chemical Burn, and then they go back to Relentless. I, however, won't perpetuate the cycle and just face them with Chemical Burn (which is at a slight disadvantage for me since they got to choose the spec last).
NIUBIHUO is a very good Barb, both in gear and in skill, among the very best I have faced. He even didn't use Threatening Shout which could have made it harder for me, but he did use Warcry.