What browser are you using that you still see pop-under ads?
It happens occasionally. I haven't used the same browser on the same computer every day for the past four years, and providing a matrix showing the pop-under-exploit-blocking capability of each one over that timeframe would be difficult.
Are you thinking of Hulu? When does Netflix do pop-unders?
For the past several years I've observed netflix pop-unders at various points on www.reelviews.net, and possibly other sites. (see my comment about using a variety of different computers and browsers over that timeframe)
Adblock?
Doesn't happen on the Wii, PS3, Xbox, iPad, iPhone and I'm guessing not on the new apple tv either.
Right, it happens when I visit other sites on a the web with a browser that doesn't block pop-unders. I'll see a big red ad with the word "Netflix" on it.