Personally I think it looks way too big and doesnt even have any hourglasses or other cards that would let you draw more than one card a turn. Depending on which set of ? ? ? is wings it might not have enough defense (but I suppose if everything is eaten you dont need much). I think it would be better if you just focused on the eating or the growth part or downsized a bit.
Also 68882 cost is a ton of electrum.

Since this is only my third or so post Im no expert, but thats just my opinion from glancing at it.