OK, I've looked at Windows Vista to see how its done there. I don't think it 
looks the best, but the text is definitely readable. I'm attaching a screenshot 
to demonstrate what they've done. In essence, they heavily blur translucent 
title bars so that there are no sharp edges shining through from the content 
behind the active window. This actually looks pretty good.
They also add an outer glow to the text in the title bar. The color of the 
outer glow is either a very pale yellow or gray. Considering that the Vista 
title bars are very transparent, I can see this is necessary, but I don't think 
it looks that great.

Ubuntu's desktop uses a carmel colored title bar that is only slightly
transparent (check that, a recent update removed transparency, but lets
assume its still slightly transparent). Therefore having a carmel
colored outer glow would mitigate problems with transparency.

For the inactive title bar, using a grey outer glow would also work.

** Attachment added: "vista transparent chrome.PNG"
   http://launchpadlibrarian.net/8580158/vista%20transparent%20chrome.PNG

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font rendering problems in Gutsy w/ compiz
https://bugs.launchpad.net/bugs/127964
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