<p>I am writing an application that needs to bring window of an external app to the foreground, and not necessarily steal focus (there is a setting the user can toggle to steal/not steal focus).</p>

<p>What is the best way to go about this using the win32 API?  I have tried SetForeground() but it always steals focus and does not consistenly work.</p>

<p>What is the best way to go about this? Any thoughts?</p>

SetForegroundWindow is supposed to steal focus and there are certain cases where it will fail.
The SetForegroundWindow function puts the thread that created the specified window into the foreground and activates the window. Keyboard input is directed to the window
Try capturing the focus with
SetCapture
prior to making the call. Also look into different ways of bringing the window to the front: SetForeGroundWindow, SetActiveWindow, even simulating a mouse click can do this.