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This should be working inside window and document blocks now. Additionally, activating a document will bring its front window in front of all other normal windows and activating a specific window will bring that window front.

I'm still not sure why Cocoa wasn't percolating this event up to the app. Anyway, this will work in window/document contexts now (though it might fail in other contexts that don't explicitly handle activate).
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CTO, The Omni Group