A windows toast message will do this, when they are triggered by other apps or the OS.
Examples:
- your email program is set to pop up a toast message when a message comes in
- a windows update notification will steal the app's focus
- adobe (or any other windows service-based updater) decides to check for an update, that resulted in a notification
- 3rd party stuff that installs tools into the system tray (AMD/NVida/Realtek "helper" utilities for example) can also send notifications.