Critters II!

[Debihuman]

Inverted behold is an interesting take on the usual critter. It has the potential to be a TPK if its hold monster ability is put to good use.

It does have a few issues. First, its initiative is +6 not +2 as it has Improved Initiative.

Eye blasts and Mouth Stalks should be two separate words.

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It's a pet peeve of mine. I hate this affectation of sticking two words together. It isn't cool and isn't literate. It just makes it harder to break people of this really bad habit when everyone uses it.

Swallow Whole should note that the inverted beholder’s gullet can hold 1 Medium, 2 Small, 8 Tiny, 32 Diminutive, or 128 Fine creatures.

I cannot tell why there are three separate saves to be made to eye blasts. Either it can make one of its attacks as a Standard Action every 1d4 rounds or it can make 3 attacks as a Standard Action every 1d4 rounds. You note three saves but say it makes one attack, which is confusing to say the least. Furthermore, using an eye blast every 1d4 rounds has potential TPK potential if hold monster comes up more than once. I really think it should be useable only once every four rounds.

Also, you should include enough information so that any DM can use this without having to look up necessary information. Since Supernatural abilities have a CL equal to creature's HD there is pertinent information you can add.
More importantly, I think Vortex should be a Reflex save to avoid rather than Fortitude save since there is no physical damage. Vortex seems like a kind of wind effect that sucks you in. May I recommend the following changes:

Eye Blasts (Su): Once every four rounds as a Standard Action, an inverted beholder can open its multiple eyes and unleash a 120-foot cone of magical energy. All opponents in the area must make a DC 17 Saving Throw against one of the effects randomly generated from the following list:

1. Hold monster causes creatures to be paralyzed as the spell for 11 rounds.A successful Will save negates the effect. If this ability is successfully used more than once, the effects overlap.
2. Ravage (see Champions of Ruin pg. 33.) causes every living creature in the area to take 5d6 points of vile damage as the spell. Unlike normal damage, vile damage can only be healed by magic cast within in area of a consecrate or hallow spell. A successful Fortitude save negates this damage.
3. Vortex: All opponents within the area of effect must make a successful Reflex save or be sucked 30 feet closer to the inverted beholder. If this puts foes in range of the inverted beholder's bite attacks, it may attack them immediately. Flying creatures that are Medium or smaller caught in the vortex are immediately grounded though they take no falling damage.Tiny or smaller creatures are knocked prone. A successful save negates this effect.

The saves are charisma-based.

You'd think its preferred tactic would be to be to ambush and use hold monster first to prevent targets from attacking. It would then use ravage on targets it didn't paralyze and use vortex on targets trying to run away.

I'd guess CR 8 (ensuring it won't be a battle of hold monster spells).

Debby