The tie breaker should be their respective records against each other.
The strength of the conferences should also factor in. Its a little easier to earn points when the competition is crap.
While I don’t disagree with the premise of your statement, t this point you should be looking more at strength of schedule rather than strength of division. The Canadiens and Leafs have as many games played against the Pacifix as the Oilers do. Buffalo has played more games against the Pacifix than the Oilers... and the Oilers have played more games against the Atlantic than the Sabres. I guess my point is, don’t assume that just because a team is in a specific division should it be automatically assumed that most of their games have been against divisional foes.