I was trying to use the code from:
to get the topmost window handle; however, I need to click a notify icon, which will bring up a form.
I tried to use

private void notifyIcon1_MouseMove(object sender, MouseEventArgs e)
    if (this.Visible == false
        && e.Button == System.Windows.Forms.MouseButtons.None)
        IntPtr x = GetForegroundWindow();
        if (x != this.Handle)
            handle = x;
        int chars = 256;
        StringBuilder buff = new StringBuilder(chars);
        if (GetWindowText(handle, buff, chars) > 0)
            notifyIcon1.Text = buff.ToString();

This correctly displays the text etc. but when I click the notify icon, it changes.

Solved. I used the get title thing to check it actually had a title.

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