How does Omnifocus avoid getting focus?

FROM : Drew McCormack
DATE : Thu Mar 13 20:45:11 2008

Omnifocus has a quick note panel that you can bring up with a hot key. 
When it comes up, Omnifocus does not become the active app, but the 
entry panel does get key focus. I know you can do this with a helper 
app, but I don't think Omnifocus is actually starting a helper app. At 
least, I don't see one in the activity monitor.

Does anyone know how you can do this: give a panel key focus without 
becoming the active app?

Drew