The study focuses on the design of aquatic toys, which is a special area of industrial toy design in general. Many times, with their various aspects, toys have been among the research subjects of several specialties. Industrial design, which deals with the subject from various perspectives, especially “toy design”, is one of these research and application areas. Although many academic studies have been carried out in the field of industrial toy design, it is seen that there is an academic gap especially in the industrial design of aquatic toys. Looking at the overall aquatic toy market, it is seen that inflatable PVC products dominate the market. This brings to mind the question of what new approaches could be in aquatic toy design. As an answer to this question, it can be said that the use of alternative materials has emerged as a remarkable option. In this sense, the idea of investigating the potentials of using PE pool noodles as an alternative design element/material in aquatic toy design constitutes the starting point of the study. In this study, an aquatic toy prototype proposal and its design process are presented in order to understand the potential of using PE pool noodles as a structural component of an aquatic toy and to exemplify the aquatic toy design which is the main subject of the research. The prototype had been evaluated by the potential users. Their comments had been depicted as findings of the analysis and suggested for further development.