Does a Beholder eye ray break its Invisibility?

[PhoenixPhyre]

Guys, there are attacks with no attack rolls, look at grapple/shove.

Yes, but those (in the fashion of D&D) are specific exceptions. If they didn't say they were attacks, they wouldn't be. So you cannot use those to reason to anything else.

Exception based games require an explicit statement of exception to basic rules. And the basic rules require an attack roll for an attack. Changing that globally breaks...lots of stuff. Many many features and spells only react/trigger on attacks. Now they trigger on anything that might be considered a hostile action. That's a huge change.