The Ur-Fish (Cydra players, stay out!)

1) At epic levels, everyone will have (or should have) freedom of movement; this negates the swallow whole. In particular, since you're going to be fighting this thing underwater, chances are FoM will be up.

2) Blindsight or true seeing would negate the miss chance.

3) The bite is nasty, but compared to, say, Ashardalon at the end of the Bastion of Broken Souls, who had 6 attacks and was dealing something like 200+ points of damage a round, it's not that bad.

I'd say the biggest problem would be the greater dispel, which could leave people drowning in short order if they get unlucky. Still, that tops out at +20 on the dispel check and it's only 1/day.

It might be more elegant to give this thing Whirlwind Attack (it's got the feats to spare) as a way of representing the sweeping bite. You can then add Improved Grab off each successful bite, if you want to swallow the entire party in one round.
 
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