EXHIBIT B2 - Foreign Settlement Program

Settling Defendants

Baxter Healthcare Corp Bristol-Myers Squibb Co. Medical Engineering Corp
Baxter International Inc. McGhan Medical Corp. (a Del. corp.)
(a/k/a McGhan Medical/3M)
Minnesota Mining & Manufacturing Co.
(a/k/a 3M Company)

Released Parties

3M Australia Pty CVI Merger Corp. Nusil Corp.
3M Canada, Inc. Derwood Faries Nusil Technologies
Aesthetech Corp. Edwards Laboratories, Inc. W. John Pangman II
American Heyer-Schulte Corp. Vicki Galati Vincent R. Pennisi
(f/k/a Heyer-Schulte Corp.) John Hartley Poly Plastic Silicone Products, Inc.
American Hospital Supply Corp. Robert J. Helbling Schulte Medical Products
Franklin L. Ashley Richard P. Jobe Diran M. Seropian
Baxter Acquisition Sub., Inc. Real Lappierre Paul Silverstein
Baxter Corporation Linvatec Corp. Sirod Corp.
Baxter Travenol Laboratories, Inc. Harold Markham H. E. Sterling
Baxter World Trade Corp. Jacqueline Markham Summit Medical Corp.
Lawrence Birnbaum Lottie Markham Kuros Tabari
Robert Bishop Markham Medical Ass'n Travenol Laboratories, Inc.
Bristol Myers Squibb Canada, Inc. Markham Medical International, Inc. Kurt Wagner
Cabot Medical Corp. Markham Surgical Specialties Edward Weck, Inc.
Angelo Cappozzi Mark/M Resources, Inc. Edward Weck & Company, Inc.
CBI Medical, Inc. Mark/M Surgical Wilshire Advanced Materials, Inc.
(a/k/a CBI Medical Electronics, Inc.) Anita Kost McAteer Wilshire Foam Products, Inc.
CooperSurgical, Inc. MEC Subsidiary Corp. Wilshire Technologies, Inc.
CooperVision, Inc. (f/k/a Surgitek, Inc.) Zimmer, Inc.
CV Sub 1987, Inc. Natural "Y" Surgical Specialties, Inc. Zimmer International, Ltd.

The "Released Parties" mean the above-listed individuals and entities, the above-listed Settling Defendants, and their respective present and former foreign and domestic parents, subsidiaries, and affiliates; their respective foreign and domestic successors, predecessors, sales representatives, independent sales representatives, distributors, transferees, insurers, and assigns; and their respective present, former, and subsequent officers, directors, agents, servants, proprietors, owners, shareholders, and employees, except that the term "Released Parties" (1) does not include doctors, hospitals, and other health-care providers who furnished medical services directly to a participant unless they are specifically named above, (2) does not include doctors specifically named above with respect to claims against them based upon their furnishing medical services directly to a participant, and (3) does not include such individuals and entities to the extent their alleged liability