The payment's timing suggests the client knew nonpublic information about the emoji's significance in the lawsuit.
Meanwhile, smiley faces and hand gestures can also indicate secret meanings – such as the upside-down face to signal annoyance, the clown emoji to signal getting caught in a mistake, or the woozy face ...
The upside-down smiley face was interpreted as sarcasm (38%), smiling through pain (36%), same as the regular smiley face (16%) or passive aggression (10%).