Interesting that GTK+ has been marked invalid & compiz added. 
One should note that this behavior occurs in unity, unity-2d, classic - both 
versions & gnome-shell

I've used the small GTK+ patch here & cannot get this to occur anymore
in any of the 5 sessions, tested in both 12.04 & 12.10

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https://bugs.launchpad.net/bugs/781931

Title:
  New windows are moved to front but don't take focus

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