From TFA, Facebook "... continues to claim that being a registered trademark holder is sufficient to be granted full access to the Whois database, and that all other routes are unduly burdensome."

So any fraudster just needs a registered trademark and they would, according to Facebook's request, be granted full access to the database.

And no oversight, as "all other routes are unduly burdensome." That means they DON'T want subpeonas or any kind of restriction in between like a judge who could evaluate the request based on some kind of merit. No limits. Just a giant straw they can use to get all that juicy data.

Facebook's request doesn't sound very good to me. Sounds great for criminals though.