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Eric, thanks for sharing some historical perspective on this Fire 
behaviour. Makes more sense this way.

>  1)  The original way that I did it automatically brought the "main"
>  window back forward after a new window showed up.  This was visually
>  jarring and difficult to deal with.

Yeah, I don't blame you for lopping that out. Sounds... suboptimal. :-)

>  2)  Fire had no way (and still really doesn't) of knowing whether
>  you were "active" in the window or if it just happened to be the
>  front most window becuase you left it that way six hours ago.

If you have a mechanism for determining that the user is idle so as 
to share that information with the messaging servers, that could be a 
plausible avenue to take in determining whether the user is likely to 
be typing, right now, in the frontmost window.

>  b)  Find a way to layer the *new* windows behind the "active" window,
>  tiled, as you suggest.  There is no trivial way to do this in X, but
>  there may be easy ways.  Or it could be a LOT of code.  I don't know.

This certainly seems the ideal solution, if it's doable. I wish luck 
to whomever considers tackling it. :-) It's the solution Eudora takes 
if the user has an unsent outgoing message frontmost; that window is 
never hidden by a newly opening window. New windows open behind it, 
so the user can keep typing in the outgoing message without worrying 
about being interrupted.

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