Mix cookie crumbs and butter until well blended. Press onto bottom of 13x9-inch pan. Refrigerate until ready to use.
Beat pudding mixes and milk in large bowl with whisk 2 min.; spread 1-1/2 cups onto bottom of crust. Stir half the COOL WHIP into remaining pudding; spread over pudding layer in pan. Cover with remaining COOL WHIP and toffee bits.