Imagine a parallel plate capacitor, where one plate is mounted on a spring and is allowed to move. Now connect a resistor across the terminals, so you have thermal noise driving the capacitor.
The reason this case is very interesting is that the force of attraction between the plates is proportional to the square of the voltage across the plates. The squaring process removes negative values and so the noise is rectified.
However, the question is how to mathematically model this system? It is more difficult than it looks.
Here is our miserable failed attempt at trying to model it:
https://www.researchgate.net/publication/10730976
What did we miss?
Article Thermodynamic energy exchange in a moving plate capacitor