Make the creamy protein fluff filling by adding protein powder, peanut butter powder, sugar free pudding mix, and xantham gum to a high powered food processor.
Blend until the ingredients are fluffy. (at least 5 minutes)
With the sugar free cookies, arrange 20 on a tray. Top with 1 tablespoon of the peanut butter cream. Top with a second cookie, and place in the freezer for about 30-40 minutes.