Comment #2 on issue 20170 by [email protected]: extension API: chrome loses  
focus when moving the last tab out of the focused window
http://code.google.com/p/chromium/issues/detail?id=20170

I created a bug on having an explicit way to focus a window: bug 20878. It  
should be
a pretty easy one.

I think you could work around this in a really hacky way by doing something  
like:
chrome.tabs.update({
   tabId,
   url: "javascript:void(window.focus())"
});

As for which window to focus when the last tab is closed, I think it should  
depend on
the OS's window stack. So if notepad would have been focused if you just  
closed the
chrome window using the close button, then we should do the same. Is that  
the current
behavior?

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