 At some point, Einfeld began claiming that he held doctorates from both "Century University" and "Pacific Western University"; both are U.S.-based diploma mills without any accreditation as law schools.Those qualifications were referred to by Attorney-General Lionel Bowen when Einfeld was added to the Federal Court in 1987, and were listed in his "Who's Who in Australia" entry until 2007.His updated "Who's Who" entry, which was published after he had been arrested and charged with perjury, also corrected his year of birth (previously listed as 1939) and removed a claim that he had once been a director of the multinational firm Marks & Spencer in the 1970s.