Perhaps they mean June 3, 1942 when Marseille claimed 6 Kittyhawks (per some sources, though 7 in OKL claims list)? He made no claims on the 6th. On the 3rd his claims and those of JG53 occurred at about the same time. A total of 9-10 Kittyhawks were claimed; 5 Sdn SAAF lost 4 Kittyhawks plus another 'force landed' back at base, an unknown RAF unit lost 2 Hurricanes apparently at around the same time; the South Africans downed at least 3 Ju-87's the Bf109's were escorting; per "Fighters Over the Desert" by Shores and Ring p. 120. The maximum claim accuracy of 70% (counting the force landing and assuming the Hurricanes were really lost in the same incident) is excellent, the minimum of 40% (counting only 4 Kittyhawks and assuming the Hurricane losses might have been to other causes) is still probably no worse than the WWII average.
On a related thread 'Hartmann's claims', two other examples of Marseille's claiming accuracy were given: Sept 1 when he claimed 17, the Germans claimed a total of 26 or 27 (varies by source), a total of 20 Allied fighters were lost, again excellent apparently ~75% claim accuracy. And, another example where it wasn't as good, Sept 15 '42 Marseille again claimed 7 Kittyhawks of 20 total Kittyhawk and 1 Spit claimed by the Germans at around 1800; but in that case only 6 Kittyhawks total were lost around that time, one attributed to AA by the Allies, plus 2 Spits time unknown, max rate ~40%, min ~25%, depending whether you accept the AA attribution and include the Spits or not.
Rudorffer flew in West too; some of his claims in Tunisia don't check out well. For example February 9th, 1943, he was credited 8 victories (6 P-40 and 2 P-38's); his unit II./JG 2, was awarded a total of 15 victories that day, 12 P-40's and 3 P-38's. The P-40's were F's of the French GC II/5, who lost 3. The P-38's were of the 94th FS, who suffered no losses; per "Focke Wulf 190 in North Africa" by Arthy and Jessen. Prorated accuracy of his claim, <20%.
It's would be a big job to do such analysis broadly, and involves uncertainties and ranges of numbers as given above, but still worthwhile IMO, even to see a few examples, as *one* input into 'who was best'. Although IMO that's a quite unanswerable question, because depends on lots of stuff besides how many planes were 'really' downed, like how hard was the overall situation for the ace's side.
On East v West front though, the German fighters probably had at least as high an overall kill ratio v the Desert Air Force in Marseille's time as the they did v the VVS in Hartmann's time, which was mainly after the 'happy times' on the Eastern Front of '41-42, he didn't start until late '42. I say that based again on "Fighters Over..." summaries of day by day combats, the Bf109's were posting a quite high real fighter-fighter kill ratio v the Hurricane/P-40/Spit opposition in that period; as say compared to total reported Soviet and German fighter air combat (and 'failed to return' in Soviet case) losses in 1944, which was still, perhaps surprisingly, in the Luftwaffe's favor but not by as high a ratio as v the Desert AF mid 1942. But as noted on that thread, a highly reliable analysis of Hartmann's claims v Soviet losses in particular incidents is yet to surface AFAIK, analyses that have been published are controversial.
Joe