mozilla-b2g/gaia — pull request #8198 by daleharvey (2013-02-20 02:16:03+00:00)
Title: Bug 836647 - Set newly created tabs to background by default

Newly created mozbrowsers default to foreground, if we open tabs
using the context menu we never set them to background leaving
a lot of fg processes. This sets them to background by default, we
already ensure to set them to foreground every time they are
needed to be so.