So I instrumented dwm with some debugs and found that the terminal was
indeed grabbing focus with an enter notify.

So I found a workaround within GNU Emacs. Non GNU Emacs users can just
look away now.

(setf (alist-get 'top ediff-control-frame-parameters) 1)
(setf (alist-get 'left ediff-control-frame-parameters) 856)

This has been tested on a grand total of one laptop, so left may need
to be tweaked.

Cheers,
   Sean

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