Yes, this was my first thought too - Facebook is essentially denial of servicing people's sites and it sounds like they're aware of it. Move fast and break your things. If this were your average Joe I'm fairly certain something like the DMCA could be used.
The DMCA has a couple major parts. The part most people are familiar with deals with safe harbor provisions and "DMCA takedowns". The relevant part for this discussion makes it illegal to circumvent digital access-control technology. So you could argue that if you have reasonable measures in place to stop automated access of your content such as robots.txt then Facebook continuing to send automated requests would be a circumvention of your access controls.
