Load current is current sourced by the Vout pin, the current through R1 is part of it. So the selection of R1 depends on the existence of an external load. If R1 will be the only load in some cases, it should consume the said minimum load current on it's own to assure regulation. If you consider worst case conditions, R1 should be as low as 120 ohm.
The topic has been discussed thoroughly in recent edaboard threads.