Naemanson - when I saw Barry Dransfield playing in the Albion Band some 40 or more years ago, I'm fairly sure he played one of the "curvy" dulcimers in guitar hold.

I can't remember whether he used a noter, but as a guitarist I'd doubt you could get the noter pressed down well enough in that position, so I suspect he used his fingers, so he could put his thumb behind for the grip.

To use a noter, I think you'd find a lap or table-top position more satisfactory.